CLA-2-29:OT:RR:NC:N3:140
Teri Johanna C. Pasinetti
Milliport Sigma
28820 Single Oak Drive
Temecula CA 92590
RE: The tariff classification of Tranilast
Dear Ms. Teri Johanna:
In your letter dated March 29, 2019 you requested a tariff classification ruling from an unspecified country
The subject product is called Tranilast (CAS #53902-12-8). You indicate that it is marketed to be used for “Research Use Only”. You state that it is an anthranilic acid analog that acts as a potent inhibitor of VEGF and vascular permeability factor-induced angiogenesis and collagen synthesis. You claim that Tranilast also inhibits VEGF and PMA stimulated PKC activity in retina capillary endothelial cells without affecting the VEGF binding or VEGF receptor phosphorylation and has anti-allergic, anti-inflammatory, and anti-proliferative properties. It also induces Ca2+ mobilization in vascular smooth muscle. Tranilast is provided in a 10mg pack size.
You indicated your opinion that Tranilast is appropriately classified in the provision 2924.29.7100. We agree with that determination.
The applicable subheading for the Tranilast will be 2924.29.7100, Harmonized Tariff Schedule of the United States (HTS), which provides for Carboxyamide-function compounds; amide function compounds of carbonic acid: Cyclic amides (including cyclic carbamates) and their derivatives; salts thereof: Other:Aromatic: Other: Products described in additional U.S. note 3 to section VI. Pursuant to GN 13, HTSUS, the general rate of duty will be free. Transilast, is listed in Table 1 of the Pharmaceutical Appendix to the Tariff Schedule.
Your letter does not indicate Tranilasts’county of origin. In the event China is determined to be the country of origin, please be advised of the following:
Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), and HTSUS. The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS. Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS. For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974). Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.83.03 or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those
Products of China classified under subheading 2924.29.7100, HTSUS, unless specifically excluded, are subject to the additional 10 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 2924.29.7100 HTSUS, listed above.
The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.
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 the World Wide Web at https://hts.usitc.gov/current.
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division