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NY N003392

November 21, 2006



TARIFF NO.: 2933.79.0800; 2936.26.0000; 2937.29.9090

Ms. Inge Forstenzer
Ren-Pharm International, Ltd.
350 Jericho Turnpike, Suite 204
Jericho, NY 11753

RE: The tariff classification of Ciclopirox Olamine (CAS-41621-49-2), Mecobalamin (CAS-13422-55-4) and Methylprednisolone (CAS-83-43-2), imported in bulk form, from Spain and Italy

Dear Ms. Forstenzer:

In your letter dated November 8, 2006, you requested a tariff classification ruling.

The first product, Ciclopirox Olamine, is an antifungal drug.

The second product, Mecobalamin, also known as “Methylcobalamin,” is one of the biologically active forms of Vitamin B12.

The third product, Methylprednisolone, is a synthetic corticosteroid (glucocorticoid) hormone used for its anti-inflammatory properties in the treatment of moderate to severe ulcerative colitis or Crohn’s disease.

The applicable subheading for Ciclopirox Olamine, imported in bulk form, will be 2933.79.0800, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Heterocyclic compounds with nitrogen hetero-atom(s) only: Lactams: Other lactams: Aromatic or modified aromatic: Other: Products described in additional U.S. note 3 to section VI." Pursuant to General Note 13, HTS, the rate of duty will be free.

The applicable subheading for Mecobalamin, imported in bulk form, will be 2936.26.0000, HTSUS, which provides for “Vitamin B12.(Cyanocobalamin and related compounds with Vitamin B12 activity) and its derivatives.” The rate of duty will be free.

The applicable subheading for Methylprednisolone, imported in bulk form, will be 2937.29.9090, HTSUS, which provides for “Steroidal hormones, their derivatives and structural analogues: Other: Other: Other.” The rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

This merchandise may be subject to the Federal Food, Drug, and Cosmetic Act and/or The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which are administered by the U.S. Food and Drug Administration (FDA). Information on the Federal Food, Drug, and Cosmetic Act, as well as The Bioterrorism Act, can be obtained by calling the FDA at 1-888-463-6332, or by visiting their website at www.fda.gov.

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 Harvey Kuperstein at 646-733-3033.


Robert B. Swierupski

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