HQ 0950582 - Classification of Trichlorocarbanilide - United States International Trade Commision Rulings

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HQ 950582
April 3, 1992

CLA-2 CO:R:C:F 950582 JGH

CATEGORY: CLASSIFICATION

TARIFF NO: 2924.21.15

Donald E. deKieffer
Pillsbury Madison & Sutro
1667 K Street N.W.
Washington, D.C. 20001

RE: Classification of Trichlorocarbanilide

Dear Mr. deKieffer:

Your inquiry of October 21, 1991, concerns the tariff classification of trichlorocarbanilide, a product of the United Kingdom, under the Harmonized Tariff Schedule of the United States (HTSUS).

FACTS:

Trichlorocarbanilide (TCC), trade name Triclocarban, is a cyclic amide of the ureine type; it is an aromatic compound said to be used as a bacteriostat in soaps for disinfectant purposes.

ISSUE:

Whether trichlorocarbanilide is classifiable under the provision for cyclic amides (including cyclic carbamates) and their derivatives; salts therof: ureines and their derivatives: Aromatic: Pesticides: in subheading 2924.21.1500, HTSUS, or as cyclic amides: ureines and their derivatives: Other: in subheading 2924.21.3000, HTSUS.

LAW AND ANALYSIS:

For tariff purposes, bactericides and disinfectants are considered pesticides, as indicated in the Explanatory Notes to heading 3808, HTSUS. Technical literature submitted in behalf of the importer shows that TCC is considered a bactericide. In Kirk-Othmer, Encyclopedia of Chemical Technology, V.7 & V.13, it is stated that TCC is an antimicrobial agent which is used almost
exclusively in deodorant soaps, and in deodorant stick formulations. Another publication recognizes its antimicrobial action in soap. Skin Microbiology- U. Cal., San Fran., School of Medicine (1979).

Based on the evidence submitted, it is concluded that the predominate use, if not the only use, of TCC is as a bactericide.

HOLDING:

Trichlorcarbonilide is classifiable under the provision for other cyclic amides and their derivatives: Ureines and their dervatives; salts thereof: Aromatic: Pesticides, in subheading 2924.21.1500, TSUS. The rate of duty is 13.5 percent ad valorem.

Previous rulings on the classification of TCC in conflict with this decision are being revoked.

Sincerely,

John Durant, Director

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