CLA-2-29:OT:RR:NC:N3:138
Robyn Brunciak
Interchem Corp
120 Route 17 North
Paramus, NJ 07652
RE: The tariff classification of Lidocaine USP (CAS No. 137-58-6) and Lidocaine Hydrochloride
Monohydrate (CAS No. 6108-05-0) in bulk powder form, from Spain
Dear Mrs. Brunciak:
In your letter dated May 19, 2025, you requested a tariff classification ruling.
Lidocaine is indicated for use as a local anesthetic, cardiac depressant, anti-arrhythmic.
Lidocaine Hydrochloride Monohydrate is the hydrochloride salt form of lidocaine. It is also chemically
designated as 2-(Diethylamino)-N-(2,6-dimethylphenyl)acetamide hydrochloride monohydrate.
The applicable subheading for the Lidocaine USP in bulk powder form will be 2924.29.5700, Harmonized
Tariff Schedule of the United States (HTSUS), 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: Drugs: Diethylaminoacetoxylidide (Lidocaine).” The
general rate of duty will be free.
The applicable subheading for the Lidocaine Hydrochloride Monohydrate in bulk powder form will be
2924.29.6250, HTSUS, 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: Drugs: Other: Other.” Pursuant to General Note 13, HTSUS, the rate of duty will be free.
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 subheadings 2924.29.5700 and 2924.29.6250, HTSUS, listed
above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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/.
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.
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 Judy Lee at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division