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NY K83791





March 22, 2004
CLA-2-29:RR:NC:2:240 K83791

CATEGORY: CLASSIFICATION

TARIFF NO.: 2925.11.0000

Mr. Emmanuel Reyes
Richwell Group, Inc.
17521 Railroad Street, Suite # H
City of Industry, CA 91748

RE: The tariff classification of Calcium Saccharin and Sodium Saccharin from China

Dear Mr. Reyes :

In your letter dated February 26, 2004 you requested a tariff classification and country of origin marking ruling.

You indicate that phthalic anhydride from Taiwan is exported to China. The phthalic anhydride is processed into methyl 2-chlorosulfonyl benzoate (O-CMB CAS 26638-43-7) in China. The O-CMB is exported to Taiwan where it is processed into insoluble saccharin. The insoluble saccharin is exported to China to be is further processed into calcium saccharin and sodium saccharin. You requested the classification of these two items and the country of origin marking

Calcium saccharin, CAS 6485-34-3, is a chemical sweetener also known as 1,2-Benzisothiazol-3(2H)-one, 1,1-dioxide, and calcium salt. Sodium saccharin, CAS 128-44-9, also a sweetener, is known as 1,2-Benzisothiazol-3(2H)-one, 1,1-dioxide, sodium salt.

The applicable subheading for calcium saccharin and sodium saccharin will be 2925.11.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for Saccharin and its salts. The rate of duty will be 6.5 percent ad valorem.

The articles ruled upon, above, may be subject to antidumping duties. A list of antidumping proceedings at the Department of Commerce (DOC) and their product coverage can be obtained from the DOC website at: http://ia.ita.doc.gov, or you may write to them at the U.S. Department of Commerce, 14th Street and Constitution Avenue, N.W., Washington, D.C. 20230. Written decisions regarding the scope of antidumping orders are issued by the Import Administration in the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs.

Your inquiry does not provide enough information for us to give a ruling on the county of origin marking. Although you have provided a general guideline to the production of calcium and sodium saccharin, important manufacturing processes are missing from your inquiry. Specify the chemicals used to react with phthalic anhydride to produce O-CMB. What chemicals were used with O-CMB to produce insoluble saccharin? Specify the chemicals and processed used to produce calcium saccharin and sodium saccharin from the insoluble saccharin. Provide a flowchart indicating all processes involved in manufacturing the calcium and sodium saccharin. Include all the names of all chemicals used in the production, and specify the resulting chemical reactions. Indicate the country of origin of all materials used in the production of the calcium saccharin and the sodium saccharin. When this information is available, you may wish to consider resubmission of your request.

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,
National Commodity

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