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NY G80309





December 18, 2000

CLA-2-29:RR:NC:2:240 G80309

CATEGORY: CLASSIFICATION

TARIFF NO.: 2918.19.2000; 2918.90.4300

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

RE: The tariff classification of 3,5-Dimethyl-p-anisic acid, CAS 21553-46-8; 4-Methoxyphenylacetic acid, ethyl ester, CAS 14062-18-1; and (RS)-alpha-Cyclohexyl-alpha-hydroxybenzeneacetic acid, CAS 4335-77-7 from France

Dear Ms. von Doehren:

In your letter dated July 26, 2000 you requested a tariff classification ruling. We apologize for the delay. The products were sent to the laboratory for analysis.

3,5-Dimethyl-p-anisic acid, CAS 21553-46-8, is also known as 4-Methoxy-3,5-dimethyl benzoic acid. The compound, a bulk pharmaceutical intermediate, is an aromatic monocarboxylic acid with an ether function. 4-Methoxyphenylacetic acid, ethyl ester, CAS 14062-18-1 is also known as 4-Methoxybenzeneacetic acid, ethyl ester. The product, a bulk pharmaceutical intermediate, is an aromatic carboxylic acid with an ether function. ( RS)-alpha-Cyclohexyl-alpha-hydroxybenzeneacetic acid, CAS 4335-77-7, a bulk pharmaceutical intermediate is an aromatic carboxylic acid with an alcohol function.

The applicable subheading for 3,5-Dimethyl-p-anisic acid and 4-Methoxyphenylacetic acid, ethyl ester will be 2918.90.4300, Harmonized Tariff Schedule of the United States (HTS), which provides for Carboxylic acids with additional oxygen function and their anhydrides, halides, peroxides and peroxyacids; their halogenated, sulfonated, nitrated or nitrosated derivatives: Other: Aromatic: Products described in additional U.S. note 3 to section VI. The rate of duty will be 9.3 percent ad valorem. The rate of duty for 2001 will be 8.6 percent ad valorem.

The applicable subheading for ( RS)-alpha-Cyclohexyl-alpha-hydroxybenzeneacetic acid will be 2918.19.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for Carboxylic acids with alcohol function, but without other oxygen function, their anhydrides, halides, peroxides, peroxyacids and their derivatives: Other: Other: products described in additional U.S. note 3 to section VI. The rate of duty will be 9.3 percent ad valorem. The rate of duty for 2001 will be 8.6 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 212-466-5768.

Sincerely,

Robert B. Swierupski
Director,

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