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June 14, 1999

CLA-2-29:RR:NC:2:240 D89938

CATEGORY: CLASSIFICATION

TARIFF NO.: 2921.30.1000; 2921.30.5000; 2932.29.3000

Ms. Joan von Doehren
Interchem Corporation
120 Route 17 North
P.O. Box 1579
Paramus, New Jersey 07653-1579

RE: The tariff classification of R-Mecamylamine salt (CAS # 107596-30-5); S- Mecamylamine salt (CAS # 107596-31-6) from Italy and Phthaladine acetic acid (CAS # 4743-57-1) from France

Dear Ms. von Doehren:

In your letter dated March 29, 1999, you requested a tariff classification ruling.

R-Mecamylamine salt, also known as (1R-Exo)-N,2,3,3,-Tetramethylbicyclo[2.2.1]-heptan-2-amine hydrochloride and S-Mecamylamine salt, also known as (1S-Exo)-N,2,3,3-Tetramethyl-bicyclo[2.2.1]-heptan-2-amine hydrochloride, are cyclanic monoamine compounds used as pharmaceutical intermediates. Phthaladine acetic acid, also known as (3-Oxo-1(3H)-Isobenzofuranylidene)acetic acid, is an aromatic oxygen heterocyclic lactone compound which you have stated will be used as a chemical intermediate.

The applicable subheading for R-Mecamylamine salt and S-Mecamylamine salt, if derived in whole or in part from any aromatic compound, will be 2921.30.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for Cyclanic, cyclenic or cycloterpenic mono- or polyamines, and their derivatives; salts thereof: Derived in whole or in part from any aromatic compounds: Other: Products described in additional U.S. note 3 to section VIĀ.. The rate of duty will be 10 percent ad valorem.

The applicable subheading for R-Mecamylamine salt and S-Mecamylamine salt, if not derived in whole or in part from any aromatic compound, will be 2921.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for Cyclanic, cyclenic or cycloterpenic mono- or polyamines, and their derivatives; salts thereof: OtherĀ.. The rate of duty will be 3.7 percent ad valorem.

The applicable subheading for Phthaladine acetic acid will be 2932.29.3000, Harmonized Tariff Schedule of the United States (HTS), which provides for Heterocyclic compounds with oxygen hetero-atom(s) only: Lactones: Other lactones: Aromatic: Other: Other: Products described in additional U.S. note 3 to section VIĀ.. The rate of duty will be 10 percent ad valorem.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Stephanie Joseph at 212-637-7066.

Sincerely,

Robert B. Swierupski
Director,

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