CLA-2-29:S:N:N7:238 892225

Ms. Joan von Doehren
Interchem Corporation
120 Rt. 17 North, Suite 115
Paramus, NJ 07652

RE: The tariff classification of Zinc orotate (CAS- 60388-02-5); Tribenzylamine (CAS-620-40-6); and 1- Phenethyl-4-piperidone (CAS-39742-60-4), all in bulk form, from Germany and France

Dear Ms. von Doehren:

In your letter dated November 3, 1993, you requested a tariff classification ruling.

Zinc orotate is a drug which is used to influence the Zn level in the mechanism of cell metabolism; Tribenzylamine [CAS registry name: N,N- bis(phenylmethyl)-benzenemethanamine] is described by you as a "chemical intermediate"; and 1-Phenethyl-4- piperidone [CAS registry name: 1-(2-Phenylethyl)-4- piperidinone] is used in the production of Fenspiride, a bronchodilator and anti-adrenergic drug. The applicable subheadings and rates of duty, under the Harmonized Tariff Schedule of the United States (HTS), for these three products will be as follows:

PRODUCT HTS RATE OF DUTY

Zinc orotate 2933.59.5900 3.7 percent ad valorem Tribenzylamine 2921.49.5000 2.4 cents per kilogram plus 18.8 percent ad valorem

1-Phenethyl-4-piperidone 2933.39.4700 13.5 percent ad valorem

This merchandise may be subject to the regulations of the Food and Drug Administration. You may contact them at 5600 Fishers Lane, Rockville, MD 20857, telephone number (301) 443-6553. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Sincerely,

Jean F. Maguire
Area Director
New York Seaport