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 Dow Chemical Company; Unused merchandise drawback; Commercial interchangeability; 19 C.F.R. §191.32(c); 19 U.S.C. §1313(j)(2); diethylene glycol.