Ms. Pam Stanford
Buckton Scott U.S.A. Inc.
330 N. Harrison Street
Princeton, New Jersey 08540
RE: The tariff classification of 4-N,N-diethyl-2-methylphenylenediamine hydrochloride, CAS 24828-38-4 from China
Dear Ms. Stanford:
In your letter dated August 16, 1999 you requested a tariff classification ruling. We apologize for the delay in issuing a ruling.
4-N, N-diethyl-2-methylphenylenediamine hydrochloride, CAS 24828-38-4, is also known as N4, N4-diethyl-2-methyl-1,4-benzenediamine hydrochloride. You state that the product is a photographic chemical used in developing oil-soluble color positive film. You suggest that the classification of the product should be in subheading 2921.51.2000 HTSUS, which provides for photographic chemicals. In order for 4-N, N-diethyl-2-methylphenylenediamine hydrochloride to be classifiable as a photographic chemical in subheading 2921.51.2000, HTSUS, it would have to be principally used for photographic proposes. A review of scientific literature indicates that although the compound can be used for photographic purposes, it is principally used as a chemical intermediate, as well as a hair dye developer.
The applicable subheading for 4-N, N-diethyl-2-methylphenylenediamine hydrochloride will be 2921.51.3000, Harmonized Tariff Schedule of the United States (HTS), which provides for Aromatic polyamines and their derivatives; salts thereof: o-, m-, p-Phenylenediamine, diaminotoluenes, and their derivatives; salts thereof: Other: Other: Products described in additional U.S. note 3 to section VI. The rate of duty will be 9.3 percent ad valorem .
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Stephanie Joseph at 212-637-7066.
Robert B. Swierupski