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NY L86499




October 17, 2005

CLA-2-29:RR:NC:2:240 L86499

CATEGORY: CLASSIFICATION

TARIFF NO.: 2918.90.4300

Mr. Joseph J. Chivini
Austin Chemical Company, Inc.
1565 Barclay Boulevard
Buffalo Grove, Illinois 60089

RE: The tariff classification of Vanillic acid ethyl ester, CAS # 617-05-0, imported in bulk form, from China

Dear Mr. Chivini:

In your letter dated July 18, 2005 you requested a tariff classification ruling.

The subject product, Vanillic acid ethyl ester, is an ester of an aromatic carboxylic acid with additional oxygen function. The product is indicated for use as a pharmaceutical intermediate.

The applicable subheading for Vanillic acid ethyl ester, also known as Benzoic acid, 4-hydroxy-3-methoxy-, 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: Other: Other: Products described in additional U.S. note 3 to section VI.. 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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