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NY N015911

August 29, 2007



TARIFF NO.: 2921.19.6090; 2933.19.3500

Ms. Erica Gardner
Granules USA Inc.
111 Howard Blvd., Suite 101
Mt. Arlington, NJ 07856

RE: The tariff classification of Isometheptene Mucate (CAS-7492-31-1) and Dichloraphenazone (CAS-480-30-8) imported in bulk form, from India

Dear Ms. Gardner:

In your letter dated August 14, 2007, you requested a tariff classification ruling.

The first product, Isometheptene Mucate is a sympathomimetic amine that constricts blood vessels.

The second product, Dichloraphenazone is a sedative that slows down your central nervous system.

Both of these products are used in combination for the treatment of acute migraine headaches.

The applicable subheading for the Isometheptene Mucate, imported in bulk form, will be 2921.19.6090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Amine-function compounds: Acyclic monoamines and their derivatives; salts thereof: Other: Other: Other: Other.” Pursuant to General Note 13, HTSUS, the rate of duty will be free.

The applicable subheading for the Dichloraphenazone, imported in bulk form, will be 2933.19.3500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Heterocyclic compounds with nitrogen hetero-atom(s) only: Compounds containing an unfused pyrazole ring (whether or not hydrogenated) in the structure: Other: Aromatic or modified aromatic: Other: Drugs.” The rate of duty will be 6.5%. At the present time, this product is not listed in the pharmaceutical appendix to the tariff schedule.

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/.

Articles classifiable under subheading 2933.19.3500 HTSUS, which are products of India, may be entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations. The GSP is subject to modification and periodic suspension, which may affect the status of your transaction at the time of entry for consumption or withdrawal from warehouse. To obtain current information on GSP, check our Web site at www.cbp.gov and search for the term "GSP".

Dichloraphenazone, may be subject to the requirements of the Controlled Substances Act, which are enforced by the U.S. Drug Enforcement Administration (DEA), Office of Diversion Control. You may contact them at 2401 Jefferson Davis Highway, Alexandria, VA 22301, telephone (800) 882-9539.

Isometheptene Mucate, 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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