CLA-2-29:OT:RR:NC:N2:238
Mr. Loren L. Howard
Peptide Research Labs, LLC
3053 E. Caballero Street
Mesa, AZ 85213
RE: The tariff classification of various sequences of amino acids from China
Dear Mr. Howard:
In your letter dated July 31, 2011, you requested a tariff classification ruling. You submitted eight products for our review and the information submitted was sent to our New York Laboratory for analysis.
You state in your letter, all of the following products listed below are sequences of amino acids.
The first product, CJC1295/ Mod GRF (1-29) with sequence: Tyr-DAla-Asp-Ala-Ile-Phe-Thr-Gln-Ser-Tyr-Arg-Lys-Val-Leu-Ala-Gln-Leu-Ser-Al-Arg-Lys-Leu-Leu-Gln-Asp-Ile-Leu-Ser-Arg-NH2. Based upon our laboratory’s analysis, this product is not called CJC1295, but rather it is called CJC1293 or Mod GRF (1-29). It is a human growth releasing factor, amino acid residues 1-29 (of 44) modified at four positions and is a structural analogue of a polypeptide hormone and is used primarily as a hormone.
The second product, CJC1295 MPA with sequence: Tyr-D-Ala-Asp-Ala-Ile-Phe-Thr-Gln-Ser-Tyr-Arg-Lys-Val-Leu-Ala-Gln-eu-Ser-Ala-Arg-Lys-Leu-Leu-Gln-Asp-Ile-Leu-Ser-Arg-Lys (Maleimidopropionyl)-H2. Based upon our laboratory’s analysis, this product is a chain modified structural analogue of a polypeptide hormone, a growth hormone releasing factor and is used primarily as a hormone.
The third product, 176-191 HGH with sequence: H-Tyr-Leu-Arg-Ile-Val-Gln-Cys-Arg-Ser-Val-Glu-Gly-Ser-Cys-Gly-Phe-OH (Disulfide Cys7-Cys14). Based upon our laboratory’s analysis, this product is a chain modified form of a polypeptide hormone and is used primarily as a hormone.
The fourth product, PEG HGH 176-191, with polyethylene glycol attached to the sequence: PEG-Tyr-Leu-Arg-Ile-Val-Gln-Cys-Arg-Ser-Val-Glu-Gly-Ser-Cys-Gly-Phe-OH (Disulfide Cys7-Cys14). Based upon our laboratory’s analysis, this product is a chain modified form of a polypeptide hormone and is used primarily as a hormone.
The fifth product, MGF, with sequence: Tyr-Gln-Pro-Pro-Ser-Thr-Asn-Lys-Asn-Thr-Lys-Ser-Gln-Arg-Arg-Lys-Gl-Ser-Thr-Phe-Glu-Glu-Arg-Lys-NH2. Based upon our laboratory’s analysis, this product is known as Mechano Growth Factor (MGF) and is a novel splice variant of the insulin growth factor (IGF-1) and is a synthetic peptide hormone.
The sixth product, PEG-MGF with polyethylene glycol attached to the sequence: PEG-Suc-Tyr-Gln-Pro-Pro-Ser-Thr-Asn-Lys-Asn-Thr-Lys-Ser-Gln-D-Arg-D-Arg-Lys-Gly-Ser-Thr-Phe-Glu-Glu-His-Lys-NH2. Based upon our laboratory’s analysis, this product is a pegylated Mechano Growth Factor and is a splice variant of the insulin like growth factor (IGF) and is a synthetic peptide hormone.
The seventh product, Melanotan II with sequence: AC-Nle-Asp-His-D-Phe-Arg-Trp-Lys-NH2. Based upon our laboratory’s analysis, this product is a synthetic analog of the naturally occurring melanocortin peptide hormone alpha-melanocyte stimulating hormone (A-MSH).
The last product, PT-141 with sequence: AC-Nle-Asp-His-D-Phe-Arg-Trp-Lys-OH. Based upon our laboratory’s analysis, this product is also known as Bremelanotide (CAS-189691-06-3), a cyclic hepta-peptide lactam analog of alpha-melanocyte stimulating hormone (Alpha-MSH) that activates the melanocortin receptors MC3-R and MC4-R in the central nervous system. It is a metabolite of the melanotan II that lacks the c-terminal amide function.
The applicable subheading for all of the products enumerated above: CJC1293/Mod GRF (1-29), CJC1295 MPA, 176-191 HGH, PEG HGH 176-191, MGF, PEG-MGF, Melanotan II, and PT-141 amino acid sequences will be 2937.19.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Hormones, prostaglandins, thromboxanes and leukotrienes, natural or reproduced by synthesis; derivatives and structural analogues thereof, including chain modified polypeptides, used primarily as hormones: Polypeptide hormones, protein hormones and glycoprotein hormones, their derivatives and structural analogues: 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 merchandise may be subject to the Federal Food, Drug, and Cosmetic Act and/or The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which are administered by the U.S. Food and Drug Administration (FDA). Information on the Federal Food, Drug, and Cosmetic Act, as well as The Bioterrorism Act, can be obtained by calling the FDA at 1-888-463-6332, or by visiting their website at www.fda.gov.
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 Judy Lee at (646) 733-3033.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division