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NY N007300

April 5, 2007



TARIFF NO.: 2922.49.8000

Mr. Eric C. Meyerhoff-Vice President
Imperial Products, Inc.,
1199 North Orange Avenue, Suite C
Orlando, Florida 32804

RE: The tariff classification of Zinc disodium ethylenediaminetetraacetate salt (ZN-EDTA) from Spain.

Dear Mr. Meyerhoff:

In your letter dated February 23, 2007, you requested a tariff classification ruling.

The compound Zinc disodium ethylenediaminetetraacetate salt (ZN-EDTA) (CAS RN 14025-21-9) is also known as Sequestrene NA 2ZN. It will be used as a fertilizer ingredient and will be imported in bulk form.

The product will be used to correct zinc micronutrient deficiencies in food crops. It is an organo-metallic complex compound (a co-ordination compound) consisting of acyclic amino acids and a zinc complex in conjunction with a disodium salt. The product is in the form of a white crystalline microgranule. Literature provided indicates that the zinc content is at least 14 percent.

The applicable subheading for the Zinc disodium ethylenediaminetetraacetate (ZN-EDTA) will be 2922.49.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: Oxygen-function amino-compounds: Amino-acids, other than those containing more than one kind of oxygen function, and their esters; salts thereof: Other: Other: Other: The rate of duty will be 3.7 percent ad valorem.

This product may be subject to the Toxic Substances Control Act (TSCA), which is administered by the U.S. Environmental Protection Agency (EPA). Information on the Toxic Substances Control Act (TSCA) can be obtained by calling the Region II office of the EPA at (212) 637-3526, or by visiting the EPA’s website at www.epa.gov.

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 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 Paul Hodgkiss at 646-733-3046.


Robert B. Swierupski

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