CLA-2-29:OT:RR:NC:N3:140
Douglas Jacobson
Jacobson Burton Kelley PLLC
1725 I Street, NW, Suite 300
Washington, DC 20006
RE: The tariff classification of Z-Lys(Z)-OH (CAS No. 405-39-0) from China in bulk form
Dear Mr. Jacobson:
In your letter dated July 31, 2025, you requested a tariff classification ruling on behalf of your client,
Veranova, L.P. We referred the information provided to our laboratory for review. We regret the delay.
The merchandise under consideration is Z-Lys(Z)-OH, also known as N2,N6-Bis[(phenylmethoxy)carbonyl]-
L-lysine, CAS No. 405-39-0. You state that it will be used as a starting material to produce an Active
Pharmaceutical Ingredient (API). In a follow up email, you indicated that the product will be imported in
bulk powder form and will consist of 100 percent of CAS No. 405-39-0.
You suggest classification in subheading 2922.41.0090 Harmonized Tariff Schedule of the United States
(HTSUS), which provides for “Oxygen-function amino-compounds: Amino-acids, other than those
containing more than one kind of oxygen function, and their esters; salts thereof: Lysine and its esters; salts
thereof: Other.” We disagree. Based on our laboratory review, Z-Lys(Z)-OH contains carboxylic acid, cyclic
carbamate, and aromatic functional groups. Therefore, it is classified elsewhere.
The applicable subheading for Z-Lys(Z)-OH will be 2924.29.7100, 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: Other: Other: Products
described in additional U.S. note 3 to section VI.” The general rate of duty will be 6.5 percent ad valorem.
The 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 ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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 (EPA). Information on the TSCA can be
obtained by contacting the EPA at Document Control Office (7407M), Office of Pollution Prevention and
Toxics (OPPT), Environmental Protection Agency, 1200 Pennsylvania Avenue, N.W., Washington, D.C.,
20460, by calling the Toxic Substances Control Act Hotline at 800-471-7127, by e-mailing to
[email protected], or by visiting their website at www.epa.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 Merari Ortiz at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division