CLA-2-35:OT:RR:NC:2:235

Ms. Nancy Quan
Snova Biotechnologies Ltd.
30 Technology Drive
Warren, NJ 07059

RE: The tariff classification of Reverse Transcriptase and DNA Polymerase Enzymes

Dear Ms. Quan:

In your letter dated May 05, 2011 you requested a tariff classification ruling.

The five products under consideration are as follows:

Product #1 TAQ DNA Polymerase is an enzyme used in PCR reaction in molecular biology experiments. TAQ DNA Polymerase is a thermostable DNA polymerase named after the thermophilic bacterium Thermus aquaticus and is frequently used in polymerase chain reaction (PCR). It is for pharmaceutical and biomedical research use, but it is not for clinical diagnostic procedure. Product #2

Hi FiFa Tth DNA Polymerase: Hi-FiFa Tth DNA Polymerase is a proofreading DNA polymerase isolated from Pyrococcus furiosus. It is for pharmaceutical and biomedical research use, but it is not for clinic diagnostic procedure.

Product #3 Ultra Tth DNA Polymerase: Ultra Tth DNA Polymerase is a thermostable enzyme derived from Thermus thermophilus. The enzyme possesses an intrinsic reverse transcriptase activity in the presence of Mn2+ ions. It is for pharmaceutical and biomedical research use, but it is not for clinical diagnostic procedure. Product #4 M-MLV (Moloney Murine Leukemia Virus) ReverseTranscriptase is a DNA polymerase that uses DNA, single-stranded RNA, or an RNA:DNA hybrid (using a primer) to synthesize complementary DNA strand. It is for pharmaceutical and biomedical research use, but it is not for clinical diagnostic procedure. Product #5 The M-MLV Reverse Transcriptase RNase H- is a genetically modified M-MLV Reverse Transcriptase which lacks RNase H activity. This recombinant enzyme was purified from E.coli. M-MLV Reverse RNase H- has RNA-dependent DNA polymerase, DNA-dependent DNA polymerase, but lack RNase H activity. It is for pharmaceutical and biomedical research use, but it is not for clinical diagnostic procedure.

Literature received with your request was forwarded to the Customs and Border Protection Laboratory for review. All five products were confirmed to consist chemically of enzymes.

The applicable subheading for all five products listed above will be 3507.90.7000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Enzymes; prepared enzymes not elsewhere specified or included: Other." The rate of duty will be Free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Paul Hodgkiss at (646) 733-3046.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division