CLA-2-34:OT:RR:NC:N3:136
Celia Tsai
Cascadia Resources Inc.
8561 154th Ave NE, Suite 220
Redmond, WA 98052
RE: The tariff classification of Wedomine OPA-10AC-100 from China
Dear Ms. Tsai:
In your letter dated April 28, 2025, you requested a tariff classification ruling on Wedomine OPA-10AC-100.
Your submission identifies the subject product as Wedomine OPA-10AC-100, CAS number
28701-67-9. You indicate that the product’s chemical name is Iso-Decyloxy Propyl Amine Acetate. The
provided documents state that Wedomine OPA-10AC-100 is a light-yellow clear liquid for use in gelation
and wetting of various clays, fillers, fibers in organic coatings, sealants, paints, and resin. Our research
indicates that Wedomine OPA-10AC-100 is a non-ionic surface-active agent.
The applicable subheading for Wedomine OPA-10AC-100 will be 3402.42.9000, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for Organic surface-active agents (other than soap);
surface-active preparations, washing preparations (including auxiliary washing preparations) and cleaning
preparations, whether or not containing soap, other than those of heading 3401: Other organic surface-active
agents, whether or not put up for retail sale: Non-ionic: Other: Other. The general rate of duty will be 3.7
percent ad valorem.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 3402.42.9000, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. Your product falls within an excepted
subheading.?At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.32, in addition to subheading 3402.42.9000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 3402.42.9000, HTSUS, unless specifically excluded, are subject to the additional 25 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 3402.42.9000, HTSUS, listed above.
The HTSUS 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. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
This merchandise may be subject to the requirements of the Toxic Substances Control Act (TSCA), which
are administered by the U.S. Environmental Protection Agency. Information on the TSCA can be obtained by
contacting the EPA at 1200 Pennsylvania Avenue, N.W., Mail Code 70480, Washington, D.C., by telephone
at (202) 554-1404, or by visiting their website at www.epa.gov.
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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. ?This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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, please contact
National Import Specialist Nuccio Fera at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division