CLA-2-29:OT:RR:NC:N3:140
Ben Lye
StarChem USA
5689 NW 35th Ct.
Miami, FL 33142
RE: The tariff classification of Dicyclohexylamine (DCHA) in bulk from Taiwan
Dear Mr. Lye:
In your letter dated September 17, 2025, you requested a tariff classification ruling.
The subject product is described as dicyclohexylamine (DCHA), CAS No. 101-83-7. You state that it
contains a purity level of 99 percent or greater and will be imported as a liquid in drums, IBC totes, or ISO
tanks. Dicyclohexylamine is used as an additive in fluids, a corrosion inhibitor, and in rubber accelerator
production.
You suggest classification in subheading 2921.30.1000, Harmonized Tariff Schedule of the United States
(HTSUS), which provides for Amine-function compounds: Cyclanic, cyclenic or cycloterpenic mono- or
polyamines, and their derivatives; salts thereof: Derived in whole or in part from any aromatic compound:
Other: Products described in additional U.S. note 3 to section VI. We disagree.
Additional U.S. Note 3(b) to Section VI, HTSUS, states that the term “products described in additional U.S.
note 3 to section VI" refers to any product not listed in the Chemical Appendix to the Tariff Schedule and (a)
For which the importer furnishes the Chemical Abstracts Service (C.A.S.) registry number and certifies that
such registry number is not listed in the Chemical Appendix to the Tariff Schedule; or (b) Which the importer
certifies not to have a C.A.S. registry number and not to be listed in the Chemical Appendix to the Tariff
Schedule, either under the name used to make Customs entry or under any other name by which it may be
known. CAS No. 101-83-7, the registry number for dicyclohexylamine, is listed in the Chemical Appendix to
the Tariff Schedule; therefore, it cannot be classified in subheading 2921.30.1000, HTSUS.
The applicable subheading for dicyclohexylamine imported in bulk will be 2921.30.3000, HTSUS, which
provides for Amine-function compounds: Cyclanic, cyclenic or cycloterpenic mono- or polyamines, and their
derivatives; salts thereof: Derived in whole or in part from any aromatic compound: Other: Other. The
general rate of duty will be 6.5 percent ad valorem.
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 Taiwan will be
subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.60, in addition to subheading
2921.30.3000, 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
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division