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NY G84846





November 30, 2000

CLA-2-29:RR:NC:2:238 G84846

CATEGORY: CLASSIFICATION

TARIFF NO.: 2922.49.2700; 2939.50.0000; 2914.70.4000; 2909.50.2000

Mr. Manan R. Patel
Prism International Inc.
3033 Meredith Place
Bensalem, PA 19020

RE: The tariff classification of Benzocaine (CAS-94-09-7); Dyphylline (CAS-479-18-5); Menadione Sodium Bisulfite (CAS-6147-37-1; CAS-130-37-0 (anhydrous)); and Potassium Guaiacolsulfonate (CAS-78247-49-1), all imported in bulk form, from China and Switzerland

Dear Mr. Patel:

In your telephone facsimile dated November 22, 2000, you requested a tariff classification ruling.

The first product, Benzocaine, is indicated for use as an anesthetic (topical).

The second product, Dyphylline (“Diprophylline” is INN), is a derivative of Theophylline, a naturally occurring xanthine alkaloid. It is indicated for use as a bronchodilator drug.

The third product, Menadione Sodium Bisulfite, is a synthetic naphthoquinone derivative having the Chemical Abstracts name of 1,2,3,4-tetrahydro-2-methyl-1,4-dioxo-2-naphthalenesulfonic acid sodium salt.

The fourth product, Potassium Guaiacolsulfonate, is indicated for use as an expectorant.

The applicable subheading for Benzocaine, imported in bulk form, will be 2922.49.2700, Harmonized Tariff Schedule of the United States (HTS), which provides for "Oxygen-function amino-compounds: Amino-acids and their esters, other than those containing more than one kind of oxygen function; salts thereof: Other: Aromatic: Other: Drugs." Pursuant to General Note 13, HTS, the rate of duty will be free.

The applicable subheading for Dyphylline, imported in bulk form, will be 2939.50.0000, HTS, which provides for “Vegetable alkaloids, natural or reproduced by synthesis, and their salts, ethers, esters and other derivatives: Theophylline and aminophylline (Theophylline-ethylenediamine) and their derivatives; salts thereof:” The rate of duty will be free.

The applicable subheading for Menadione Sodium Bisulfite, imported in bulk form, will be 2914.70.4000, HTS, which provides for: “Ketones and quinones, whether or not with other oxygen function, and their halogenated, sulfonated, nitrated or nitrosated derivatives: Halogenated, sulfonated, nitrated or nitrosated derivatives: Aromatic: Other.” Pursuant to General Note 13, HTS, the rate of duty will be free.

The applicable subheading for Potassium Guaiacolsulfonate, imported in bulk form, will be 2909.50.2000, HTS, which provides for “Ether-phenols, ether-alcohol-phenols and their halogenated, sulfonated, nitrated or nitrosated derivatives: Guaiacol and its derivatives.” Pursuant to General Note 13, HTS, the rate of duty will be free.

This merchandise may be subject to the requirements of the Federal Food, Drug, and Cosmetic Act, which is administered by the U.S. Food and Drug Administration. You may contact them at 5600 Fishers Lane, Rockville, Maryland 20857, telephone number 301-443-1544.

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 Harvey Kuperstein at 212-637-7068.

Sincerely,

Robert B. Swierupski

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