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HQ 954920

July 19, 1994

CLA-2 CO:R:C:F 954920 EAB


TARIFF NO.: 3402.11.1000

Mr. Keith Welch
Unger Fabrikker A.S
P.O. Box 254
N-1601 Fredrikstad

RE: Linear alkylbenzene sulfonic acid (LABSA); CAS 27176-87-0 not listed in Chemical Appendix; "UFACID K"; "UFACID KA"

Dear Mr. Welch:

This is in reply to your letter dated August 17, 1993, concerning the classification under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA) of linear alkylbenzene sulfonic acid made in Norway from U.S. alkylbenzene. Your question regarding the country of origin of the product and possible duty reductions will be addressed in a separate ruling from another branch of this office.


Alkylbenzene of U.S. origin is shipped to Norway, where it is reacted with sulfur trioxide to produce linear alkylbenzene sulfonic acid sold, we presume in the U.S., under the brand names of "UFACID K" and "UFACID KA."

LABSA, also known as dodecylbenzenesulfonic acid, is assigned Chemical Abstract Series No. 27176-87-0, a number not listed in the Chemical Appendix to the Tariff Schedule.


What is the tariff classification of linear alkylbenzene sulfonic acid that is made in Norway from U.S. alkylbenzene?


Merchandise imported into the U.S. is classified under the HTSUSA. Tariff classification is governed by the principles set forth in the General Rules of Interpretation (GRIs) and, in the absence of special language or context which otherwise requires, by the Additional U.S. Rules of Interpretation. The GRIs and the Additional U.S. Rules of Interpretation are part of the HTSUSA and are to be considered statutory provisions of law for all purposes.

GRI 1, requires that classification be determined first according to the terms of the headings of the tariff schedule and any relative section or chapter notes and, unless otherwise required, according to the remaining GRIs taken in order.

LABSA is classified under subheading 3402.11.1000, HTSUSA, a provision for anionic aromatic surface active agents.


Linear alkylbenzene sulfonic acid made in Norway from U.S. alkylbenzene is classified under subheading 3402.11.1000, HTSUSA, a provision for "Organic surface-active agents (other than soap); surface-active preparations, washing preparations (including auxiliary washing preparations) and cleaning preparations, whether or not containing soap, other than those of heading 3401: Organic surface-active agents, whether or not put up for retail sale: Anionic: Aromatic or modified aromatic."

Merchandise classified under the foregoing provision is dutiable at the column one general rate of 7.2 percent ad valorem.


John Durant, Director

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