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HQ 230237

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February 10, 2005

DRA-4-RR:CR:DR 230237 IOR

CATEGORY: DRAWBACK

Port Director
Customs and Border Protection
2350 N. Sam Houston Parkway East
Suite 1000
Houston, TX 77032-3126

Attn: Lynne Sakaki-Lee

RE: AFR 5301-03-100001; drawback; commercially interchangeable; naphtha; gasoline; 19 U.S.C. 1313(j)(2)

Dear Sir:

The above-referenced protest was forwarded to this office for further review. We have considered the points raised by the protestant and your office, and our decision follows a July 21, 2004 teleconference between counsel for the protestant and staff of this office, as well as a submission dated September 13, 2004, made on behalf of the protestant. Our decision follows:

FACTS:

The protest is of the liquidation, without drawback, of drawback entries, TA2-xxxx008-2 (“008-2”), and TA2-xxxx007-4 (“007-4”), filed by Clarendon (Glencore) Marketing, Inc. (“drawback claimant”) under 19 U.S.C. §1313(j)(2).

The drawback claim 008-2 designated 303,279 barrels of the 516,670 bbl. of regular unleaded gasoline imported by Clarendon Marketing Co., on December 25, 1990, on the “AMBIA FAIR”, by entry 474-xxxx877-8. On the CF 7501, the merchandise is described as 516,670 bbl. of “unleaded gasoline motor fuel”, exported from Romania on December 8, 1990, and is classified under subheading 2710.00.15153, Harmonized Tariff Schedule of the United States (HTSUS). The per barrel value of the imported merchandise can be determined from the entered quantity and value information on the CF 7501. An undated certificate of quality for merchandise from the “AMBIA FAIR” vessel tank, for “regular unleaded gasoline of Romanian origin” has been provided. With respect to the imported merchandise, a “deal ticket” dated December 21, 1990 has been submitted. It is not clear what the “deal ticket” represents.

With respect to the imported merchandise, in the United States Court of International Trade, Court No. 92-08-00574, on April 15, 2003, it was stipulated that the merchandise imported under import entry 474-xxxx877-8, was “classifiable as naphtha under 2710.00.25 HTS.” Entry 474-xxxx877-8 was reliquidated on August 8, 2003, at a lower rate of duty in accordance with classification of the merchandise under subheading 2710.00.25, HTSUS.

Drawback is claimed on the basis of one exportation of merchandise on the vessel “FOLEGANDROS”. On a bill of lading dated September 10, 1993, it is stated that 303,279.17 bbl. of “in bulk gasoline” was clean on board the “FOLEGANDROS” on September 10, 1993, destined for Nigeria. Two certificates of analysis for the exported merchandise were provided, one of which describes the merchandise as a “gasoline blend,” and one of which describes the merchandise as “gasoline.”

With regard to the export, the file contains a Shipper’s Export Declaration (“SED”), an invoice for the sale of the domestic gasoline, a “purchase out of oil tanking” document referencing the “FOLEGANDROS” and bill of lading of September 10, 1993, and assignments of drawback rights to the protestant with regard to the exported merchandise. The SED submitted is largely illegible, however it shows that 303,279 units of gasoline, classified in subheading 2710.00.1518, was exported to Nigeria on the “FOLEGANDROS”. The value of the merchandise is also provided on the SED, from which the per barrel value can be determined. The information on the invoice dated September 13, 1993, is consistent with the information on the bill of lading and that which can be read on the SED. The invoice is from Clarendon LTD. The “purchase out of oil tanking” describes three different transactions with the same quantity and price, but it is not clear what is represented. The first assignment of drawback rights is from Oiltanking Houston, Inc. to Clarendon LTD., and the second assignment of drawback rights is from Glencore Ltd., formerly Clarendon Ltd., to Glencore Marketing Inc., formerly Clarendon Marketing, Inc.

The results on the certificates of analysis for the imported and exported merchandise which is the subject of claim 008-2 are as follows:

PROPERTY

IMPORT

EXPORT

Specifi-
Cation
Result
Specifi-
Cation
Result
Gum content. (mg/100 mls)
5 max.
2.8
5max
50.4

MTBE
NIL

Research Octane Number
89.9
87.4
Motor Octane Number
80.4
85.2

In a laboratory report from the Customs and Border Protection (“CBP”) Laboratories and Scientific Services, dated May 19, 2004, it was stated that the imported and exported merchandise which is the subject of claim 008-2 are not commercially interchangeable for the reasons that 1) the imported merchandise was stipulated to be NAPHTHA, 2) the imported merchandise passed the gum content specification for gasoline, while the exported merchandise failed the gum specification for gasoline, 3) gasoline above octane 87 should be considered different to gasoline with an octane between 85 and 87, and 4) the imported merchandise was shown to indicate that methyl-tert-butyl ether (MTBE) was not present, and the export had no result for MTBE.

The drawback claim 007-4 designated 266,198 bbl. of the 386,309 bbl. of premium unleaded gasoline imported by Clarendon Marketing, Inc. on April 20, 1991 on the “STAR OREGON”, by entry 784-xxxx464-9, and on May 20, 1991 on the “TEAM ERVIKEN”, by entry 458-xxxx243-7.

For entry 784-xxxx464-9, on the CF 7501, the merchandise is described as 149,546 bbl. of “unleaded gasoline motor fuel”, exported from the United Kingdom on April 9, 1991, and is classified under subheading 2710.00.15153, HTSUS. The per barrel value of the imported merchandise can be determined from the entered quantity and value information on the CF 7501. An analytical report dated April 23, 1991 for merchandise from the “STAR OREGON” for “premium unleaded gasoline” has been provided. In addition, with respect to the import, there is a document regarding payment for merchandise, referencing the “STAR OREGON” in which the merchandise is described as “premium unleaded gasoline”, and in which the quantity discharged corresponds to the entered amount of merchandise. There are also two “deal tickets” one dated April 16, 1991 and one dated April 10, 1991. It is not clear what sale the deal tickets represent. The deal ticket dated April 16, 1991 does make a reference to “3% MTBE max” in the specifications.

For entry 458-xxxx243-7, on the CF 7501, the merchandise is described as 236,763 bbl. of “premium unleaded gasoline with an A.P.I. Gravity of 55.8”, exported from Saudi Arabia on May 1, 1991, and is classified under subheading 2710.00.15153, HTSUS. The per barrel value of the imported merchandise can be determined from the entered quantity and value information on the CF 7501. A report of laboratory analysis dated May 21, 1991 for merchandise from the “TEAM ERVIKEN” for “prem. no lead” has been provided. In addition, the September 13, 2004 submission included a May 2, 1991 laboratory analysis based on a sample from the shore tank at the Saudi Arabian loading port.

Drawback is claimed on the basis of one exportation of merchandise on the vessel “PRODICOS”. On a bill of lading dated April 29, it is stated that 266,197.52 bbl. of “premium unleaded gasoline” was to be shipped on board the “PRODICOS” destined for Curacao. A certificate of analysis for the exported merchandise was provided, which describes the merchandise as “premium unleaded gasoline.”

With regard to the exported merchandise, the file includes an “Oil Tanking Pricing Formula” referencing the “PRODICOS “B/L 4/29/93”, and assignments of drawback rights. The pricing formula document references the sale of 266,197.52 bbl. for a stated amount. One assignment of drawback rights is an assignment from Novacor Chemicals LTD. to Clarendon LTD., with respect to 266,197.52 bbl. of premium unleaded gasoline said to have been exported to the Netherlands Antilles on April 29, 1993 aboard the “PRODICOS”. The second assignment of drawback rights is an assignment from Glencore Ltd., formerly Clarendon Ltd. to Glencore Marketing Inc, formerly Clarendon Marketing Inc., with respect to 266,197.52 bbl. of premium unleaded gasoline said to have been exported to Curacao on April 29, 1993 aboard the “PRODICOS”.

The results on the certificates of analysis for the imported and exported merchandise which is the subject of claim 007-4 are as follows:

PROPERTY

IMPORTS

EXPORT

Specifi-
Cation
Result
Specifi-
Cation
Result

STAR OREGON
TEAM ERVIKEN

MTBE
3.0

Research Octane Number
98.3
97.2
95 min.
99.1
Motor Octane Number
86.7
87.4
87.6
92.5
92.3
93 min
93.4

In a laboratory report from CBP Laboratories and Scientific Services, dated May 19, 2004, it was stated that based on the octane index alone, the imported and substituted merchandise which is the subject of claim 007-4 could meet the industry standard criterion for commercial interchangeability. However, the industry standard criterion cannot be met with regard to the imported and exported merchandise without 1) information regarding the MTBE content of the merchandise imported on the TEAM ERVIKEN and for the exported merchandise, and 2) information on the percent alcohols and parts per million sulfur. While the May 2, 1991 loadport analysis reported a sulfur content which meets the ASTM D 4814 specification requirement, it was rejected by the CBP Laboratories and Scientific Services, in a follow up report of November 17, 2004, as not representative of the imported merchandise at the time of importation.

The drawback entries were liquidated with no drawback on October 4, 2002. The instant protest was filed by Glencore, Ltd. (“protestant”) on December 30, 2002. The protest takes the position that the imported and exported merchandise are commercially interchangeable and therefore the drawback claims should be allowed. In the protest it is asserted that the imported and substituted merchandise meet the ASTM D 4814 “Standard Specification for Automotive Spark-Ignition Engine Fuel”, and that the imported and substituted merchandise are all classified under subheading 2710.00.1518, HTSUS. With respect to relative value of the imported and substituted merchandise in claim 0008-2, it is asserted that the value for the export is based upon the sale to Nigeria, a third-world nation.

Glencore Ltd. asserts that it has standing to file the protest as the legal successor to Clarendon Marketing, Inc. The importer in all cases was the same entity as the drawback claimant, having the same taxpayer Identification number. The protest asserts that as of September 1, 1994, the name of Clarendon Marketing, Inc. was changed to Glencore Marketing, Inc. (the file includes a document substantiating such name change), and as of October 11, 1996 Glencore Marketing, Inc. was merged into Glencore Ltd., which has a different taxpayer identification number from the importer and drawback claimant.

In its transmittal of the subject AFR, in a memorandum dated December 17, 2003, the drawback unit commented that the drawback claims had been denied because the claimant had not been able to provide sufficient information to the CBP laboratory so that a determination of commercial interchangeability could be made, and because the import in one of the claims had been stipulated to be naphtha.

ISSUE:

Whether the drawback claimant has met the statutory and regulatory requirements for drawback under 19 U.S.C. §1313(j)(2).

LAW AND ANALYSIS:

We note that the protest was timely filed under the statutory and regulatory provisions for protests (see 19 U.S.C. §1514 and 19 CFR Part 174). Customs liquidated the entries on October 4, 2002 and the protest was filed on December 30, 2002. In addition, we conclude that Glencore Ltd. has standing to protest on behalf of the drawback claimant.

Under 19 U.S.C. §1313(j)(2), as amended, drawback may be granted if there is, with respect to imported duty paid merchandise, any other merchandise that is commercially interchangeable with the imported merchandise and if the following requirements are met. The other merchandise must be exported or destroyed within three years from the date of importation of the imported merchandise. Before the exportation or destruction, the other merchandise may not have been used in the United States and must have been in the possession of the drawback claimant. The party claiming drawback must either be the importer of the imported merchandise or have received from the person who imported and paid any duty due on the imported merchandise a certificate of delivery transferring to that party, the imported merchandise, commercially interchangeable merchandise, or any combination thereof. The issues before us in this case are commercial interchangeability of the imported and substituted merchandise, possession of the substituted merchandise, and whether exportation of commercially interchangeable substituted merchandise has been established.

Compliance with the Customs Regulations on drawback is mandatory and a condition of payment of drawback (United States v. Hardesty Co., Inc., 36 CCPA 47, C.A.D. 396 (1949); Lansing Co., Inc. v. United States, 77 Cust. Ct. 92, C.D. 4675; see also, Guess? Inc. v. United States, 944 F.2d 855, 858 (1991) ("We are dealing [in discussing drawback] with an exemption from duty, a statutory privilege due only when the enumerated conditions are met")).

The drawback statute was substantively amended by section 632, title VI Customs Modernization, Pub. L. No. 103-182, the North American Free Trade Agreement Implementation ("NAFTA") Act (107 Stat. 2057), enacted December 8, 1993. Before its amendment by Public Law 103-182, the standard for substitution was fungibility. House Report 103-361, 103d Cong., 1st Sess., 131 (1993) contains language explaining the change from fungibility to commercial interchangeability. According to the House Ways and Means Committee Report, the standard was intended to be made less restrictive, i.e., "the Committee intends to permit substitution of merchandise when it is "’commercially interchangeable,' rather than when it is "’commercially identical’" (the reference to "commercially identical" derives from the definition of fungible merchandise in the Customs Regulations, prior to their amendment in 1998 (19 C.F.R. 191.2(l)). The report, at page 131, also states:

The Committee further intends that in determining whether two articles were commercially interchangeable, the criteria to be considered would include, but not be limited to: Governmental and recognized industry standards, part numbers, tariff classification, and relative values.

The Senate Report for the NAFTA Act (S. Rep. 103-189, 103d Cong., 1st Sess., 81, 85 (1993)) contains similar language and states that the same criteria should be considered by Customs in determining commercial interchangeability. The amended Customs Regulations, 19 CFR 191.32(c), provide that in determining commercial interchangeability:

...Customs shall evaluate the critical properties of the substituted merchandise and in that evaluation factors to be considered include, but are not limited to, Governmental and recognized industrial standards, part numbers, tariff classification and value.

In order to determine commercial interchangeability, Customs adheres to the Customs Regulations which implement the operational language of the legislative history. The best evidence whether those criteria are used in a particular transaction are the claimant’s transaction documents. Underlying purchase and sales contracts, purchase invoices, purchase orders, and inventory records show whether a claimant has followed a particular recognized industry standard, or a governmental standard, or any combination of the two, and whether a claimant uses part numbers to buy, sell, and inventory the merchandise in issue. The purchase and sale documents also provide the best evidence with which to compare relative values. Also, if another criterion is used by the claimant to sort the merchandise, the claimant’s records would show that fact which will enable Customs to follow the Congressional directions.

The statutory provision for substitution unused merchandise drawback, 19 U.S.C. §1313(j)(2)(ii), is the following:

(2)if there is, with respect to imported merchandise on which was paid any duty, tax, or fee imposed under Federal law because of its importation, any other merchandise (whether imported or domestic) that-- (A) is commercially interchangeable with such imported merchandise;and (C) before exportation or destruction - (i) is not used within the United States, and (ii) is in the possession of, including ownership while in bailment, in leased facilities, in transit to, or in any other manner under the operational control of, the party claiming drawback under this paragraph, if that party- (I) is the importer of the imported merchandise,...

In this case, given that drawback rights were assigned to the drawback claimant, it appears that the drawback claimant was not the exporter of the domestic substituted merchandise. There is no evidence regarding the drawback claimant’s transactions with the exporter, therefore there is insufficient evidence to determine whether the drawback claimant had possession of the domestic substituted merchandise. The documents consisting of the “purchase out of oil tanking”, invoice, and “oil tanking pricing formula”, do not provide any discernible information regarding possession of the exported merchandise by the drawback claimant.

The copies of the bills of lading which were provided were neither original nor certified copies. Further, the bill of lading for the shipment on the “PRODICOS” does not have a date on which the merchandise was laden, nor does it have a year on the date (although based on the other documentation it appears that the year was 1993. Because the bills of lading submitted are neither original nor certified copies, the date and fact of exportation have not been provided for the asserted exports, as required under 19 CFR 191.72.

Generally, in order to determine whether the imported and exported merchandise is commercially interchangeable, an analysis of the factors below, as set forth in 19 CFR 191.32(c) is required. With regard to claim 008-2 however, we take the position that because the imported merchandise was stipulated to be naphtha in the United States Court of International Trade, Court No. 92-08-00574, on April 15, 2003, the imported merchandise is clearly not commercially interchangeable with gasoline, the substituted merchandise. Naphtha is not a motor fuel, unlike gasoline. Rather, naphtha is used for blending in producing motor gasoline, as well being used as dry-cleaning fluid and as solvent in the manufacture of paints. The Illustrated Petroleum Reference Dictionary, R. Langenkamp, Ed.( 1982 2d ed.), 137. The merchandise cannot be claimed to be one thing for purposes of importation, naphtha, and then another, unleaded gasoline, for purposes of claiming drawback. However, we address the commercial interchangeability for claim 008-2 below as well.

The entry of the imported merchandise which was designated in drawback claim 008-2, was in fact reliquidated on August 8, 2003. The reliquidation was in accordance with the stipulation in Court No. 92-08-00574, at a lower rate of duty in accordance with classification of the merchandise as naphtha, under subheading 2710.00.25, HTSUS, which is a commodity other than the fuel which is asserted to have been exported. The classification was pursuant to a final decision in the Court of International Trade, in Court No. 92-08-00574.

Governmental and Recognized Industry Standards

The industry standard for unleaded gasoline is ASTM D 4814. In the Laboratories and Scientific Services report of May 19, 2004, it was concluded that the imported merchandise for claim 008-2 met the gum content specification, and the merchandise asserted as exported on the “FOLEGANDROS” did not meet the gum content specification. In addition, the import was tested for MTBE, and specifically was found not to have MTBE. There is no indication whether or not the substituted merchandise had MTBE. None of the documents submitted pertaining to the substituted merchandise provide any information whether the merchandise was bought or sold as with or without MTBE. Additives such as MTBE affect the performance of the product. Finally, the imported merchandise was classified and reliquidated in accordance with a final decision of the Court of International Trade, as naphtha, and the import and export would not be subject to the same industry standards, as ASTM D4814 does not pertain to naphtha, but to engine fuel.

With regard to the merchandise which is the subject of claim 007-4, the laboratory report of May 19, 2004 concluded that insufficient specifications from ASTM D 4814 were provided. Specifically, the laboratory concluded that additional information was required for MTBE, percent alcohols, and parts per million sulfur for each of the imports and the substituted merchandise. For example, an MTBE content was provided for the merchandise imported on the “STAR OREGON”, but not for the merchandise imported on the “TEAM ERVIKEN” or the substituted merchandise. The sulfur content was provided for the substituted merchandise, but was not provided for either of the imports (for the import on the “TEAM ERVIKEN” the sulfur content was only included in the loadport analysis, which does not reflect the condition of the imported merchandise). With regard to the MTBE, none of the transaction documents submitted pertaining to the imported and substituted merchandise provide any information whether the merchandise was bought or sold as with or without MTBE.

With respect to claim 008-2, we find that the imported and substituted merchandise are not the same type of merchandise and therefore do not meet this criterion of commercial interchangeability. With respect to claim 007-4, we find that the information contained in the certificates of analyses, combined with the lack of transaction documents, is insufficient to establish that the imported and substituted merchandise meet this criterion for commercial interchangeability.

2. Tariff Classification

For claim 008-2, according to the CF 7501, the imported merchandise was classified in subheading 2710.00.1515, HTSUS. According to the SED, the exported merchandise was classified in subheading 2710.00.1518, HTSUS. The tariff classification for the import and the export initially were the same (2710.00.151, HTSUS), through the ninth digit. However, as stated above, in claim 008-2, the imported merchandise was stipulated in the Court of International Trade, Court No. 92-08-00574, as “classifiable as naphtha under 2710.00.25 HTS,” and reliquidated as such, in accordance with the final decision of the Court of International Trade. Therefore, the classification of the imported and exported merchandise is not the same through the eighth digit.

For claim 007-4, according to the CF 7501, the imported merchandise was classified in subheading 2710.00.1515, HTSUS. Other than the assertion made in the protest we have no evidence regarding the tariff classification of the exported merchandise.

We find that the merchandise in claim 008-2, does not meet this criterion for commercial interchangeability, based on the classification of the imported merchandise as stipulated in the Court of International Trade. With respect to claim 007-4, we find that this criterion for commercial interchangeability is met, provided that the assertion of the protestant as to the classification of the export can be substantiated.

Part Numbers

We do not find that there is evidence that the subject merchandise is bought or sold pursuant to part numbers, and this criterion is inconclusive in the determination of commercial interchangeability.

Relative Values

In claim 008-2, the value of the imported merchandise is 44% higher than the value of the substituted merchandise. In the protest, the difference is asserted to be explained by the fact that the merchandise was being exported to a third world country. We do not find that the difference in value between the import and substituted merchandise precludes commercial interchangeability.

In claim 007-4, in the case of the import on the “TEAM ERVIKEN”, the value of the substituted merchandise is 6.39% higher than the value of the import. In the case of the import on the “STAR OREGON”, the value of the imported merchandise is 3.8% higher than the value of the substituted merchandise. We find that the little difference in the value of the imported and substituted merchandise supports a determination of commercial interchangeability.

On the issue of commercial interchangeability for claim 008-2, we find that the imported and substituted merchandise is not commercially interchangeable, because the industry and government standard, and tariff classification criteria are not met, and the remaining criteria of commercial interchangeability do not specifically support a finding of commercial interchangeability.

On the issue of commercial interchangeability for claim 007-4, we find that the imported merchandise and the substituted merchandise is not commercially interchangeable because insufficient information was provided to establish that the merchandise meets the same industry standards for the governmental and industry standard criterion, and the criterion of part numbers was determined to be inconclusive. The tariff classification criterion requires substantiation, and the relative value criterion alone cannot establish commercial interchangeability.

The protestant takes the position in its submissions, that the imports and exports for each drawback claim meet the standard for commercial interchangeability set forth in Texport Oil Co. v. United States, 185 F.3d 1291 (Fed. Cir. 1999). In Texport, the CAFC stated that "a firmly objective standard—analyzed from the perspective of a hypothetical reasonable competitor" avoids the concerns of overbroad descriptions of merchandise on transaction documents, prone to manipulation, and the "analysis might also include evidence of arms-length negotiations between commercial actors, the description of the goods on bills of sale or invoices." 185 F3d at 1295. The court stated that "’commercially interchangeable’ must be determined objectively from the perspective of a hypothetical reasonable competitor; if a reasonable competitor would accept either the imported or the exported good for its primary commercial purpose, then the goods are ‘commercially interchangeable’". Id. In Texport, the CAFC cautioned against reliance on overly broad or vague descriptions in commercial documents. Further, the decision in Texport, supports a decision to rely on the descriptions of the actual merchandise at issue.

With respect to claim 008-2, the drawback claim describes the imported and exported merchandise as “regular unleaded gasoline,” and the import documents describe the imported merchandise as “unleaded gasoline motor fuel,” however it is clear from the Court of International Trade stipulation and the subsequent liquidation, that the imported merchandise was naphtha. Therefore, with respect to claim 008-2, the descriptions in the documentation are suspect and not reliable, as they are inconsistent with the subsequent stipulations and liquidations. Further, there is no evidence, or basis to believe that a reasonable competitor purchasing naphtha would accept “regular unleaded gasoline” as a substitute, or that a reasonable competitor purchasing “regular unleaded gasoline” would accept naphtha as a substitute.

With respect to claim 007-4, both the imported and exported merchandise are claimed to be “premium unleaded gasoline,” however the specifications provided were insufficient to establish that the merchandise met the standard for unleaded gasoline. Very few transaction documents were provided, and reliance on those, which gave no specifications for the merchandise, would be contrary to the standard set forth in Texport, which was intended to avoid reliance on overbroad descriptions of merchandise in transaction documents. CBP has nothing other than the specifications to consider. Finally, the documentation for the imports did address MTBE. One of the deal tickets submitted made a reference to MTBE, and the certificate of analysis for the import on the STAR OREGON reported the presence of MTBE. Given that MTBE is specified in some instances and tested for and reported in some instances, it does not appear that a reasonable competitor purchasing unleaded gasoline with MTBE would accept unleaded gasoline without MTBE as a substitute, or that a reasonable competitor purchasing unleaded gasoline without MTBE would accept unleaded gasoline with MTBE.

HOLDING:

In claims 008-2, and 007-4, the imported merchandise and substituted merchandise are not commercially interchangeable for purposes of 19 U.S.C. §1313(j)(2). With respect to both drawback claims we find that the drawback claimant has not met the requirements for establishing possession of the substituted merchandise by the drawback claimant, and has not supplied sufficient evidence of the exportation of the substituted merchandise.

The protest should be denied. In accordance with the Protest/Petition Processing Handbook (CIS HB, June 2002, pp. 18 and 21), you are to mail this decision, together with the CBP Form 19, to the protestant no later than 60 days from the date of this letter. Any reliquidation of the entry in accordance with the decision must be accomplished prior to mailing of the decision. Sixty days from the date of the decision the Office of Regulations and Rulings will make the decision available to CBP personnel, and to the public on the CBP Home Page
on the World Wide Web at www.cbp.gov, by means of the Freedom of Information Act, and other methods of public distribution.

Sincerely,

Myles B. Harmon, Director

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See also:

• Tariff No.: 2710.00.15 - Motor fuel, from petro oils and bitumin. minrls, o/than crude, or preps. 70%+ by wt. from petro. oils
• Tariff No.: 2710.00.25 - Naphthas (ex. motor fuel or mtr fuel blend. stock), fr. petro oils and bitumin. minrls, o/than crude, or preps. 70%+ by wt. fr. petro. oils