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and R' may be the same or different. You claim that since di-penta does not contain either an alkyl or an aryl group (althoughit does have the R-O-R structure), di-penta does not satisfy theENs definition of ethers and should not, therefore, be classifiedas such. You also point out that the ether content of di-pentaaccounts for none of its chemical activity; that the chemicalactivity displayed is entirely attributable to the hydroxylgroups characteristic of penta and polypentaerythritols. As aresult you suggest that di-penta be classified as polyhydricalcohol derived from sugars in subheading 2905.49.2000, HTSUS. This would be appropriate you believe as polyhydric alcohols arecompounds containing multiple OH groups, and di-penta containssix OH groups. You state that it is derived from formaldehyde,acetaldehyde, and an alkaline condensing agent, which combine tocreate pentaerythose, a sugar, with some formaldehyde left over;the sugar and formaldehyde then react to give a combination

The tariff classification of Xylitol (CAS # 87-99-0), Phenolphthalein (CAS # 77-09-8), Reneck Salt (CAS # 13573-16-5), Potassium Tetraoxlate, Dihydrate (CAS # 6100-20-5), Biuret (CAS # 108-19-0) and N-Phenyl Glycine Sodium Salt (CAS # 10265-69-7) from Japan

The tariff classification of Isomalt, a mixture of sorbitoland mannitol from West Germany.

Crystalline Xylitol

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