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NY 887708

July 16, 1993

CLA-2-29:S:N:N7:240 887708


TARIFF NO.: 2929.10.3000

Mr. Stanley Bernard
Cedar Chemical Corporation
5100 Poplar Avenue Suite 2414
Memphis, TN 38137

RE: The tariff classification of 3,4-dichlorophenylisocyanate from France and Brazil

Dear Mr. Bernard:

In your letter dated June 25, 1993, you requested a tariff classification ruling.

You plan to export 3,4-dichloroaniline, CAS 608-31-1, to either France or Brazil to be processed into 3,4-dichlorophenylisocyanate, CAS 102-36-3, also known as 1,2-dichloro-4-isocyanato benzene. This manufacturing process produces a different product. This constitutes a substantial transformation, therefore, the product becomes the product of either France or Brazil.

The applicable HTS subheading for 3,4-dichlorophenylisocyanate, CAS 102- 36-3, also known as 1,2-dichloro-4-isocyanato benzene will be 2929.10.3000, Harmonized Tariff Schedule of the United States (HTS), which provides for 3,4- dichlorophenylisocyanate. The duty rate will be 2.9 cents per kilo plus 16.2 percent ad valorem.

The Generalized System of Preference (GSP) expired at midnight July 4, 1993. There is the possibility that legislation will be enacted that will renew GSP retroactively to its date of expiration. In the event that this occurs, articles classifiable under subheading 2929.10.3000, HTS, which are the products of Brazil, would be entitled to duty free treatment under GSP upon compliance with all applicable regulations.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have already been filed, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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