CLA-2-29:OT:RR:NC:N3:140
Ludger Heiliger
Chem - Solutions GmbH
Julius-Wilde- Sre. 3
Neustadt 67434
Germany
RE: The tariff classification of 2,2-Dichlorophenylacetic acid, ethyl ester (CAS No. 5317-66-8), from India
Dear Dr. Heiliger:
In your letter dated August 13, 2025, you requested a tariff classification ruling.
The subject product is described as 2,2-Dichlorophenylacetic acid, ethyl ester, CAS No. 5317-66-8. You
indicate that it contains a minimum purity level of 98 percent and will be imported in bulk shipments.
The applicable subheading for the 2,2-Dichlorophenylacetic acid, ethyl ester imported in bulk will be
2916.39.1700, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Unsaturated
acyclic monocarboxylic acids, cyclic monocarboxylic acids, their anhydrides, halides, peroxides and
peroxyacids; their halogenated, sulfonated, nitrated or nitrosated derivatives: Aromatic monocarboxylic
acids, their anhydrides, halides, peroxides, peroxyacids and their derivatives: Other:
2,2-Dichlorophenylacetic acid, ethyl ester; and m-Toluic acid.” The general rate of duty will be Free.
Effective August 27, 2025, Executive Order 14339 imposed additional duties on products from India. At this
time, products of India provided by heading 9903.01.84, except for products described in headings
9903.01.85 – 9903.01.89, will be subject to an additional ad valorem rate of duty of 25 percent. At the time
of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.84, in
addition to subheading 2916.39.1700, 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 of India will be
subject to an additional ad valorem rate of duty of 25 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.26, in addition to subheading
2916.39.1700, 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 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
Acting Director
National Commodity Specialist Division