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January 31, 1997
CLA-2 RR:TC:SM 559936 BLS


Port Director
P.O. Box 2748
Mobile, Alabama 36652-2748

RE: Eligibility of diuron products for duty-free treatment under the GSP; double substantial transformation; IA 11/96

Dear Madame:

This is in reference your letter dated March 14, 1996, forwarding a request for internal advice (IA 11/96) submitted on behalf of IDA, Inc. ("IDA") and Drexel Chemical Company ("Drexel"), concerning the eligibility of certain diuron products from Malaysia for duty-free treatment under the Generalized System of Preferences (GSP) upon importation into the U.S. We have also received a supplemental submission from counsel, dated December 20, 1996.


IDA and Drexel are importers of Industrial Grade Diuron, Technical Grade Diuron and Diuron 80 WP (wettable grade), products whose primary use has been as herbicides for agricultural and industrial applications where selective control of undesirable plant growth is desired. Certain chemicals of non-Malaysian origin are shipped to Malaysia where the following processing is performed.

Diuron Cake

The first stage of production involves the manufacture of diuron cake by Polytensides Sdn Berhad ("Polytensides"). During this process, solid 3,4 dichlorophenyl isocyanate ("DCPI") is liquefied by the application of heat. It is then pumped into reactors in specified amounts with a 60% solution of aqueous anhydrous dimethylamine ("DMA") and toluene. Both DCPI and DMA are of non-Malaysian origin. The constituents are blended for approximately 15 minutes. After the blending, the manufacturer allows an exothermic reaction to run unhindered for
approximately another 15 minutes. Following that reaction, the mixture is cooled for approximately 120 minutes, with the aid of water circulating around the outside of the reactor and through a heat exchange unit.

The remaining required quantities of DMA and DCPI are then added to the reactor, followed by approximately 15 minutes of mixing. The manufacturer again permits an exothermic reaction to run unhindered for another 15 minutes. The end result of these reactions is a mixture of water, toluene, DMA, amorphous diuron and minor impurities.

The constituents of this mixture are then separated by a process called azeotropic distillation, forming pure amorphous diuron at the end of the process. The distillation process removes DMA, then water, then toluene. The crude amorphous diuron remaining at this point still has a trace of toluene that is difficult to remove, but here is removed by using a vacuum and a higher temperature.

After azeotropic removal of DMA and water and the distillation of toluene, the temperature of the remaining constituents is about 125 degrees centigrade and a vacuum is applied to the crude amorphous diuron. The toluene and any other remaining volatile hydrocarbons are removed at this step and the amorphous diuron melts to a liquid diuron. The vacuum and heating are continued for about 30 minutes to ensure all aromatics have been removed. During the increase of temperature the amorphous crude diuron is changed into a molten diuron liquid.

The molten crude diuron is heated to about 155 degrees centigrade at full vacuum for 30 minutes. The vacuum is slowly released while holding the temperature at 150-155 degrees centigrade. Stainless steel trays are placed below the reactor where one set of trays will hold one reactor of crude molten diuron. The molten material is run into stainless steel trays that are arranged so that the liquid fills each tray. After filling, the trays are allowed to cool by forced air circulation. The diuron is crystallized into diuron cakes that are safe to handle and have no irritating odor, unlike the DCPI. The cooling process takes about 8 hours to complete. Once cooled, the product is diuron cake, which has a solid crystalline structure. The importer states that this product consists of diuron in its purest form, and can be used to make pesticide, a growth inhibitor for paint, or can be used as a stabilizer in the industrial diuron production of plastic resins.

When cooled to ambient temperature, the wheeled trays are moved to the storage area and the larger diuron cakes are broken into smaller pieces and stored in open-top drums until further production is required. From start to finish, the diuron cake production process takes approximately 8 hours.

Industrial Diuron

The diuron cake is then moved to the separate facility of Ancom Berhad ("Ancom"), where it will be formulated into specific products, including herbicides such as Diuron Technical and Diuron 80 WP as well as paint additives or plastic stabilizers. These products require different formulating techniques.

Counsel states that in order to formulate Diuron Technical and Diuron 80 WP, the pure diuron cake must be changed into a product which has smooth flowable characteristics, and which disperses well and adheres to plant surfaces in an effective manner. This is achieved by a process which combines and coats the diuron with specially purified silicas and clays so that the solid crystalline chunks will be changed to flowable particles in the 10 to 20 micron size range.

The process begins by breaking the diuron cake into pieces of from 6 to 12 inches by 2 inches thick. The diuron cake pieces are placed in a crusher blender that reduces the size from 6 to 12 inches to about 200 micron size. This process takes approximately 60 minutes. The crude diuron is then placed in open-top drums for storage before being processed into further industrial grades of diuron for further manufacturing into usable products.

Next, the 200 micron crystalline diuron is ground into an industrial grade of about 120 micron size by using a mixture of silica and clay with the diuron particles. The silica is a specially purified silica of from 2 to 4 microns size, and the clay of approximately 5 micron size.

Counsel states that the role of the silica and clay is critical, since the diuron alone will not remain in the powder state, but will agglomerate into larger pieces which are unusable for the purposes desired by IDA/Drexel. The importer explains that the adherence of the clay and silicon is accomplished through the vehicle of Van der Waal forces, which are forces of attraction occurring between atoms and molecules. While much weaker than chemical bonds, the importer states that these are the forces
holding molecules together in molecular crystals. This attraction is further enhanced by electrostatic charges built up during the grinding and blending process. This is an ongoing process during the various grinding and blending steps, with the free silicon adhering to new uncoated diuron surfaces created in the particle size reduction and processing. If silicon was not added, the diuron crystals would stick together by electrostatic forces and in the agglomerated form would be unusable as a herbicide.

The crushed crystalline diuron is next placed in a ribbon blender with 0.5% silica and 0.5% clay of the magnesium-aluminum-silicate type and blended for approximately 15 minutes to reduce the diuron into smaller pieces and to coat those pieces with silica until all the surface areas are treated.

The free-flowing industrial diuron is stored in open-top drums for further manufacturing into usable pesticide formulations. IDA/Drexel states that all diuron products to this point cannot be used as agricultural products and are not sold as such. However, the inquirer points out that industrial diuron has been used in a number of non-agricultural applications including use as a paint additive and as a plastic stabilizer.

Diuron Technical

Industrial Grade Diuron is then subject to further processing with silica and clay to produce Diuron Technical. The Industrial Diuron is placed in a ribbon blender and both silica and clay are added. The importer states that about 1.0% silica and 0.5% clay are added to adjust the finished concentration to 96-97% diuron. (It is noted in this regard that this statement appears to conflict somewhat with the supporting material, which describes Diuron Technical as containing a minimum of 97% diuron.) The mixture is well blended in the ribbon blender and then fed into the pin mill hopper. The Industrial Diuron is taken to a pin mill that also has a classifer attached. The blended diuron fed into the pin mill is ground to about 10 micron size using an air classifer to separate and regrind the diuron. The blending in the ribbon mill, then the pin mill is the most lengthy in the entire manufacturing process, with the ribbon blender taking approximately 6.5 hours.

The resulting product is Diuron Technical, a free flowing diuron powder, ready to grind further for reformulation into a Diuron 80 WP form or a liquid, flowable form. The Diuron Technical product is now suitable for agricultural use if combined with a surfactant and dispersant. This final step is done either by Ancom, in the case where it sells IDA and Drexel 80 WP, or by Ida and Drexel, where Ancom exports Diuron


Diuron 80 WP

The manufacture of Diuron 80 WP mirrors the production of Diuron Technical, except that, in addition to adding silica and clay in the ribbon blender/pin mill phase of the operation, Ancom also adds a surfactant and dispersant to arrive at the 80% concentration of pure diuron. The importer advises that while a number of surfactants would be suitable for use with diuron, the one used in this case is monylphenolethoxylate. The dispersing agent used by Ancom is usually either alkylnapthalenosulflonate or ligninsulfonate. The production of Diuron 80 WP is approximately 1.5 hours longer than the process for Diuron Technical.

Counsel states that both the dispersant and the surfactant are critical to the product's ultimate use as a pesticide. The addition of the surfactant ensures that the diuron will adhere to and remain on the surface of the weed or plant which is the target of the pesticide. The dispersant ensures that when the diuron is placed in suspension by the farmer or person using the pesticide that it remains in suspension over a reasonable period of time.

It is argued that as a result of the described operations the chemicals imported into Malaysia are substantially transformed into diuron cake which is an intermediate article of commerce and which is itself substantially transformed into new and commercially distinct products by subsequent manufacturing operations which change its name, character and use. Therefore, counsel contends that the chemicals imported into Malaysia are subjected to a double substantial transformation and the cost or value of such materials may be counted in determining the 35 percent value-content requirement under the GSP.


Whether the chemicals imported into Malaysia (DCPI and DMA) undergo a double substantial transformation so as to permit the cost or value of these chemicals to be used in calculating the 35 percent value-content requirement under the GSP.


Under the GSP, eligible products of a designated beneficiary developing country (BDC) which are imported directly into the U.S. qualify for duty-free treatment if the sum of the cost or value of the materials produced in the BDC plus the direct costs involved in processing the eligible article in the BDC is at least 35% of the article's appraised value at the time of its entry into the U.S. See 19 U.S.C. 2463.

The cost or value of materials which are imported into the BDC to be used in the production of the article, as here, may be included in the 35% value-content computation only if the imported materials undergo a double substantial transformation in the BDC. That is, the non-Malaysian chemicals must be substantially transformed in Malaysia into a new and different intermediate article of commerce, which is then used in the production of the final imported article. See 19 CFR 10.177(a).

The test for determining whether a substantial transformation has occurred is whether an article emerges from a process with a new name, character or use, different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 69 CCPA 152, 681 F.2d 778 (1982). This determination must be based on the totality of the evidence. See National Hand Tool Corp. v. United States, Slip Op. 92- 61 (April 27, 1992), aff'd, 989 F.2d 1201 (1993).

In determining whether a substantial transformation occurs in the manufacture of products from chemicals, Customs has consistently examined whether a chemical reaction occurs when two chemicals are mixed in the production of the final article. See Headquarters Ruling Letters (HRLs) 555248 dated April 9, 1990; 556064 dated March 29, 1990; 555403 dated June 6, 1990; and 055652 dated May 18, 1979. When chemical compounds are mixed together to form a different substance and the individual properties of each ingredient are no longer discernable, they have undergone a substantial transformation. See HRL 555989 dated June 24, 1991, in which we held that raw materials used to produce three varieties of antioxidants undergo a double substantial transformation in the Bahamas.

We are of the opinion that the production of the diuron cake from the chemicals imported into Malaysia results in a substantial transformation of the
imported materials into a "product of" Malaysia. These chemicals are transformed into a new product with unique chemical properties and a commercial identity distinct from its constituent chemical compounds. The question which we must now address is whether the diuron cake is an intermediate article of commerce which itself is substantially transformed into the final products, Diuron Technical and Diuron 80 WP. In this regard, and as noted above, the steps required to complete the production of Diuron Technical and Diuron 80 WP from the diuron cake do not involve any additional chemical reactions.

Counsel argues that the diuron cake is an intermediate article of commerce, which can be bought and sold at any time, and is sold to a related party, to be formulated into the final product. In this regard, counsel states that at this stage the diuron cake can also be formulated into a paint additive or a plastic stabilizer, as well as a pesticide. In support of a double substantial transformation, counsel cites the case of Torrington Co. v. United States, 764 F.2d 1563, 1568 (Fed. Cir. 1985). Torrington held that a double substantial transformation occurred abroad when wire was transformed into swaged needle blanks, which were then transformed into sewing needles. The court in Torrington found that the swaged needle blanks were "producer's goods" different than the finished consumer's goods, needles, and held that such goods were intermediate articles of commerce.

Counsel urges that the ruling in Torrington is directly applicable to the facts at issue, in that the diuron cake is a "producer's good" which is an identifiable article which can be bought and sold at any time. Thus, he points out that the diuron cake is sold to a related party, who processes it into the finished product, a consumer's good which, he states, is a new and different article from the diuron cake from which the finished good was made.

We have limited Torrington to the specific factual situation found therein--the dual substantial transformation of sewing needles. See T.D. 86-7, dated December
20, 1985, 20 Cust. Bull. 7 (1986). Therefore, we do not recognize Torrington as precedent for this case. However, even if we were to consider Torrington, it is factually distinguishable from the present case, since we do not consider the manufacture of pesticides in the instant case to be analogous to the manufacture of sewing needles.

We believe that the court's decision in National Juice Products v. United States,

628 F. Supp. 978, 10 CIT 48 (CIT 1986), a country of origin marking case, provides guidance for determining whether a second substantial transformation results from the additional processing of the diuron cake. In National Juice, the court determined that imported frozen concentrated orange juice was not substantially transformed in the U.S. when it was domestically processed into retail orange juice products. In that case, manufacturing concentrate produced abroad was shipped to the U.S., where it was blended with other ingredients (primarily water) to create an end product of either frozen concentrated orange juice or reconstituted orange juice. This process involved mixing the manufacturing concentrate with purified and de-chlorinated water, orange essences, orange oil, and, in some instances, fresh juice.

In National Juice, the court addressed each of the factors -- name, character and use -- in finding that no substantial transformation occurred in the production of retail orange juice products from manufacturing concentrate. The court found that the change in name from "concentrated orange juice for manufacturing" to "frozen concentrated orange juice" and "orange juice from concentrate" was not significant to a finding of a substantial transformation. Instead, the court stated that these names "merely refer to the same product, orange juice, at different stages of production." Id. at 989.

The court agreed with Customs that the imported manufacturing concentrate "imparts the essential character to the juice and makes it orange juice. . . [and thus], ..., the imported product is the very essence of the retail product." The court found that the retail product in this case was essentially the juice concentrate derived in substantial part from foreign grown, harvested, and processed oranges. Although the addition of the water, orange essences, and oils to the orange juice concentrate made it suitable for retail sale, according to the court, this did not change the fundamental character or use of the product, as it was still essentially the product of the juice of oranges.

In Azteca Milling Co. v. United States, 703 F. Supp. 949 (CIT 1988), aff'd, 890 F.2d 1150 (Fed. Cir. 1989), corn grown in the U.S. was sent to Mexico where it was removed from the cob, cleaned, and then cooked with lime, to produce "nixtamal." Nixtamal was then steeped and washed, resulting in a product identified as "masa." The masa was then ground and flash dried, and after cooling, was sifted into flour. In that case, the court found the nixtamal, masa, and tamale flour remained clearly recognizable as processed corn, and that a dual substantial transformation had not
occurred since none of the intermediate products lost the essential identifying characteristics of corn. See also Zuniga a/c Refractarios Monterrey, S.A. v. United States, Slip Op. 92-89 (CIT June 12, 1992), where the court held that the production of kiln furniture in Mexico from several dry ingredients of U.S. origin through a multiple step processing operation did not constitute a double substantial transformation, since none of the products resulting from those steps, i.e., castables, casting slip, or greenware, was considered a new and different intermediate article of commerce which lost the "identifying characteristics" of its constituent components.

In HRL 734558 dated July 22, 1992, also involving the mixing of various substances, Customs addressed the manipulation of a herbicide and found that there was no substantial transformation when the herbicide, exported in bulk to France, was encapsulated into a water-soluble film. In that case, Customs pointed out that the operation did not change the chemical composition of the herbicide but only facilitated its use. See also HRL 555064 dated March 29, 1990, where Customs determined that the formulation of propanil-4, a herbicide for rice, from technical propanil did not constitute a substantial transformation for purposes of the Caribbean Basin Economic Recovery Act (CBERA). This decision was based on T.D. 78- 168, 12 Cust. Bull. 353 (1978), which held that the formulation of the herbicide diuron wettable powder by mixing technical diuron with various agents was not a substantial transformation for purposes of the GSP. The findings in these cases are also consistent with the court's reasoning in National Juice, supra, since in both cases the processing did not change the fundamental character of the imported product.

The principles reflected in the cited cases are also well defined in a number of Customs decisions which hold that the mere refining or purification of a crude substance does not result in a substantial transformation of the substance into a new and different article of commerce with a new name, character or use. In HRL 556143 dated March 2, 1992, Customs held that for purposes of the 35% value-content requirement under the CBERA, purification of Crude Octamine (85-87 percent purity) into Octamine R (97 percent purity) did not result in a substantial transformation. In that case, the claimed intermediate product, Crude Octamine, was sold as a low grade aviation lubricant, while the imported product was sold as a high-grade aviation lubricant. While the crude product in that case was clearly an article of commerce, Customs found that Octamine R had the same chemical structure as Crude Octamine, and that the removal of impurities and ultimate refinement was not sufficient to change the essential character of the low-grade
lubricant. See also Coastal States Marketing, Inc. v. United States, 10 CIT 613, 646 F. Supp. 255 (1986), aff'd 818 F.2d 860 (Fed. Cir. 1987), where the court held that the process of blending Russian No. 2 gas oil with Italian No. 5 fuel oil in Italy did not substantially transform the Russian oil into a product of Italy. The court stated that the blended product was not a new and different article, but simply variant grades of the same product identified as fuel oil, with the resulting blend also identified as fuel oil.

In another case involving the refinement of a crude substance, HRL 554644 dated October 29, 1987, we held that the processing of crude linseed oil into a fully refined oil did not result in a substantial transformation. The refining process in this case involved the dry caustic neutralization of the fatty acids which was achieved through heating and mixing the oil with sodium hydroxide. The fatty acids were dispersed converting the acids and oil into water and soapy matter. The oil was moved to centrifugal washers and separators, removing the soaps. After centrifuging, all of the remaining water was removed from the oil by vacuum drying. We held in HRL 554644 that:

While it is clear that the processing of the crude linseed oil into a refined product results in a purified, higher grade oil with less contaminants and odor, the essential character is not altered and it does not become a new and different article of commerce. The removal of impurities and ultimate refinement is not sufficient to effect any major change in the product."

See also HRL 554637 dated July 13, 1987 (processing of raw sugar into a refined product results in purified sugar with less contaminants, which is not a new and different article of commerce; HRL 082033 dated September 5, 1989 (refining cane sugar upgrades and purifies the sugar, but it does not change the essential character of the product); C.S.D. 84-112 dated July 2, 1984 (HRL 724640) (imported honey which was purified by heating and filtering did not undergo a substantial transformation), and HRL 555982 dated August 2, 1991 (evaporation of water from orange juice and subsequent freezing in a CBERA BC does not change the fundamental character of the imported juice).

In HRL 557830 dated August 19, 1994 (affirmed upon reconsideration in HRL 558852 dated December 21, 1994), we held that the distillation of raw ethyl alcohols feedstocks into hydrous ethyl alcohol and then removal of water by a molecular sieve
process to produce anhydrous ethyl alcohol did not result in a substantial transformation for purposes of the U.S.-Israel Free Trade Implementation Act ("FTA"), as the final product retained the essential character of the raw ethyl alcohols feedstocks. In that case, we noted that both the hydrous ethyl alcohol and anhydrous ethyl alcohol were considered "ethanol" in the chemical and commercial sense, and that anhydrous ethyl alcohol had the same chemical and molecular structure as the material from which it was made. We stated that the additional processing involving the removal of the water from the hydrous ethyl alcohol was not sufficient to effect a substantial change in the chemical composition or "essence" of the product, as this product still possessed the identifying characteristics of the material from which it was derived - raw ethyl alcohols feedstocks. Therefore, we held that the processing of the raw feedstocks, which included removing the water from the hydrous ethyl alcohol to produce anhydrous ethyl alcohol by means of the molecular sieve process, did not result in a substantial transformation of the raw ethyl alcohols feedstocks.

While the instant case does not involve the refining or purification of a crude product, but rather the addition of silica, clay and other inert ingredients to make the diuron cake a usable good, in our opinion the underlying issue to be resolved is essentially the same, i.e., whether the processing of a crude product which does not involve any chemical reaction results in a change in name, character and use. In this regard, we note that the final products continue to be identified as Diuron (i.e., Diuron Technical and Diuron 80 WP), and consist of materials of which diuron constitutes approximately 80 percent (Diuron 80 WP) and 96-97 percent (Diuron Technical).

We also find that the processing of the diuron cake in this case is analogous to the operations performed in National Juice, supra, which involved the blending with other ingredients (primarily water) of manufacturing concentrate to create an end product of either frozen concentrated orange juice or reconstituted orange juice.
In that case, as noted, the court found that the retail product was essentially the juice concentrate, and that although the addition of the water, orange essences, etc., made it suitable for retail sale, the fundamental character of the product remained unchanged.

Counsel also relies on other authorities, including Koru North America v. United States, 12 CIT 1120, 701 F. Supp. 229 (1988), a country of origin marking case, in
support of a second substantial transformation. Counsel argues that Koru, and not
National Juice, is analogous to the facts in the instant case.

In Koru, fish were caught on the high seas near New Zealand where they were beheaded, detailed, eviscerated and frozen, then off loaded in New Zealand. The fish were subsequently shipped to Korea for further processing which consisted of thawing, gutting, beheading, skinning, boning, trimming, glazing, refreezing and packaging for exportation to the United States. The court held that this further processing in Korea effected a substantial transformation of the fish so that the country of origin of the fish was Korea. The court reached this holding in view of the fact that the processing in Korea created a new and different article - an individually quick frozen fish fillet - from one having the appearance (largely) of a whole fish. The court found the fillets to be a separate product which is sold in separate areas and markets, and found in this processing changes in the name, character, and use of the article. Moreover, the court distinguished National Juice by finding that the changes resulting from the processing "go to the fundamental nature and character of the fish..." Id. Such changes included a change in the shape, marketing and tariff classification of the fish resulting from the processing.

Counsel believes that a second substantial transformation is also supported by HRL 733814 dated June 24, 1991, in which Customs relied on Koru in finding that the processing of green coffee beans into instant coffee resulted in a product with a new character and use. Counsel also cites in support of a substantial transformation HRL 554308 dated November 24, 1986, clarified by HRL 543895 dated April 20, 1987, where Customs found a single substantial transformation where naproxen and naproxen sodium were each mixed with certain materials and water and tableted to a prescription drug dosage of the products Naprosyn and Anaprox; HRL 556235 dated December 24, 1991, where we found that a substantial transformation occurred when sugar syrup was combined and processed with corn syrup to produce hard candy; C.S.D. 85-12, involving the vulcanization of inner tubes; and United States v. International Paint Co., 35 CCPA 87, C.A.D. 376 (1948), where the court found a substantial transformation based on the different uses of a paint to which the blending of an additive (varnish) and removal of impurities made it suitable for use in marine applications.

In our opinion, the cited cases do not support the finding of a second substantial transformation in the instant case. In Koru, the evisceration of a fully formed fish
into a filleted fish resulted in a fundamental change to the essential character of the final product, a change in our opinion that is not present in the instant case. A similar finding was made in HRL 556235, as the hard candy is clearly a different product from the ingredients from which it was made, and also in HRL 733814, a country of origin marking case which involved the transformation of green coffee beans to instant coffee. (It is further noted that unlike the diuron cake which itself was the result of extensive processing, the fish in Koru and the coffee beans in HRL 733814 were raw products which had undergone no processing until the operations occurred which resulted in their conversion to the final product.) International Paint involved a claim for drawback, and as a result, Customs is not bound by the decision in that case. C.S.D. 85-12 concerned a product (rubber tires) and operations totally distinct from the processing involved in the instant case, and as a result, we do not find this case to be in point. Finally, we do not find HRL 554308 to be applicable since, as distinguished from the present situation, we found that each of the completed products had a new name, character and use distinct from the chemicals from which they were made.

In summary, based on the principles set forth in National Juice, and supported by HRL 557830 and other Customs decisions involving the refinement and purification of various products, we find that the fundamental character and use of the diuron cake is unchanged by the subsequent processing performed in Malaysia, which results in the imported products Diuron Technical and Diuron 80 WP. Accordingly, we find that only one substantial transformation takes place in Malaysia, and that the cost or value of the materials imported into Malaysia cannot be included in calculating the 35% value-content requirement under the GSP.


The production of Diuron Technical and Diuron 80 WP in Malaysia constitutes a single substantial transformation. As a result, while the imported products are considered products of Malaysia for purposes of the GSP, the cost or value of the materials imported into Malaysia for purposes of producing Diuron Technical and Diuron 80 WP cannot be included in determining the 35% value-content requirement under the GSP.

This decision should be mailed by your office to the internal advice requestor no later than 60 days from the date of this letter. On that date the Office of Regulations and Rulings will take steps to make the decision available to Customs personnel via the Customs Ruling Module in ACS and the public via the Diskette Subscription Service, Lexis, Freedom of Information Act and other public access channels.


John Durant,

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