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NY H88182




March 25, 2002

CLA-2-29:RR:NC:2:240 H88182

CATEGORY: CLASSIFICATION

TARIFF NO.: 2921.29.0010; 2921.29.0020; 2921.29.0055

Mr. Kazuhiko Saito
Toho Boeki Co., Ltd.
Kurihara Toranomon Bldg.
20-5, Toranomon 1-Chome
Minato-Ku
Tokyo, Japan

RE: The tariff classification of Tetraethylenepentamine (CAS 112-57-2), Triethylenetetramine (CAS 112-24-3) and Pentaethylenehexamine (CAS 4067-16-7) from Japan

Dear Mr. Saito:

In your letter dated January 39, 2002 you requested a tariff classification ruling.

Ruling H84285 had been issued to you on Tetraethylenepentamine (CAS 112-57-2), Triethylenetetramine (CAS 112-24-3) and Pentaethylenehexamine (CAS 4067-16-7). You have provided additional information concerning the manufacturing process of these compounds. The technical information submitted shows the manufacturing process of these compounds with various peaks. The peaks, according to your information, are the various isomers produced as byproducts during the manufacturing of each compound. The isomers are formed synchronously during the process of the production. They have almost the same boiling point, and therefore, cannot be separated utilizing standard industrial methods such as distillation. The number of N groups identifies the various isomers. Triethylenetetramine, known as TETA in your literature, has 4 N groups; Tetraethylenepentamine, known as TEPA, has 5 N groups; Pentaethylenehexamine, known as PEHA, has 6 N groups. Chapter 29 Note 1 (b) provides for mixtures of two or more isomers of the same organic compound (whether or not containing impurities) except mixtures of acrylic hydrocarbon isomers (0ther than stereoisomers) whether or not saturated (chapter 27). We requested information to determine whether these isomers were purposely left in the compound to serve a specific function. You have indicated that the isomers are not purposely left in the product, nor do they render the products useful for a specific purpose

The applicable subheading for Tetraethylenepentamine, also known as 1,2-Ethanediamine, N-(2-aminoethyl)-N'-[2-[(2-aminoethyl)amino]ethyl]- will be 2921.29.0010, Harmonized Tariff Schedule of the United States (HTS), which provides for Acyclic polyamines and their derivatives; salts thereof: Other: Tetraethylenepentamine. The rate of duty will be 6.5 percent ad valorem.

The applicable subheading for Triethylenetetramine also known as Trientine, will be 2921.29.0020, Harmonized Tariff Schedule of the United States (HTS), which provides for Acyclic polyamines and their derivatives; salts thereof: Other: Triethylenetetramine. The rate of duty will be 6.5 percent ad valorem. Pursuant to General Note 13 to the Harmonized Tariff Schedule, this product will be free of duty.

The applicable subheading for Pentaethylenehexamine, also known as 3,6,9,12-Tetraazatetradecane-1,14-diamine will be 2921.29.0055, Harmonized Tariff Schedule of the United States (HTS), which provides for Acyclic polyamines and their derivatives; salts thereof: Other: Other. The rate of duty will be 6.5 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 646-733-3268.

Sincerely,

Robert B. Swierupski
Director,

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