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NY I89156

January 29, 2003

CLA-2-29:RR:NC:2:240 I89156


TARIFF NO.: 2918.90.4300; 2925.19.4200

Mr. Bill Gottschalk
Hexagon Organics, LLC
P.O. Box 2445
Danbury, CT 06813-2445

RE: The tariff classification of 4,4’-Diaminodiphenylmethanebismaleimide, CAS # 13676-54-5, 4,4’-Oxydibenzoic acid, CAS # 2215-89-6 and 4,4’-Oxydibenzoic acid chloride, CAS # 7158-32-9, imported in bulk form, from the United Kingdom

Dear Mr. Gottschalk:

In your letter dated December 13, 2002, you requested a tariff classification ruling.

The subject product, 4,4’-Oxydibenzoic acid, also known as 4,4'-Oxybisbenzoic acid, is an aromatic carboxylic acid with an additional oxygen function (ether). The compound, 4,4’-Oxydibenzoic acid chloride, also known as 4,4’-Oxybisbenzoyl chloride, is an aromatic carboxylic acid halide (chloride) with an additional oxygen function (ether). The compound 4,4’ Diaminodiphenylmethanebismaleimide, also known as 1H-Pyrrole-2,5-dione, 1,1'-(methylenedi-4,1-phenylene)bis-, is an aromatic carboxyimide-function compound.

The applicable subheading for 4,4’-Oxydibenzoic acid and 4,4’-Oxydibenzoic acid chloride 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: Aromatic: Other: Other: Products described in additional U.S. note 3 to section VI.. The rate of duty will be 7.2 percent ad valorem.

In your letter, you suggest classification under 2925.19.9000 for the compound 4,4’ Diaminodiphenylmethanebismaleimide. This provision provides for nonaromatic carboxyimide-function compounds. Based on the chemical structure, this is an aromatic carboxyimide-function compound. The word “aromatic” is defined as a major group of unsaturated cyclic hydrocarbons containing one or more rings, typified by benzene, which has a 6-carbon ring containing three double bonds. Therefore, the applicable subheading for 4,4’ Diaminodiphenylmethanebismaleimide will be 2925.19.4200, Harmonized Tariff Schedule of the United States (HTS), which provides for Carboxyimide-function compounds (including saccharin and its salts) and imine-function compounds: Imides and their derivatives; salts thereof: Other: Aromatic: Other.. The rate of duty will be 7.4 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.


Robert B. Swierupski

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