The tariff classification of Ciclopirox (CAS-29342-05-0) and Imiquimod (CAS-99011-02-6), imported in bulk form, from Spain

NY K88042 August 12, 2004 CLA-2-29:RR:NC:2:238 K88042 CATEGORY: Classification TARIFF NO.: 2933.79.0800; 2933.99.7000 Ms. Inge Forstenzer Ren-Pharm International, Ltd. 350 Jericho Turnpike, Suite 204 Jericho, NY 11753-1317 RE: The tariff classification of Ciclopirox (CAS-29342-05-0) and Imiquimod (CAS-99011-02-6), imported in bulk form, from Spain Dear Ms. Forstenzer: In your letter dated July 23, 2004, you requested a tariff classification ruling. The first product, Ciclopirox, is a broad-spectrum, antifungal agent indicated for the topical treatment of various skin infections, such as tinea pedis, tinea cruris, cutaneous candidiasis, and tinea versicolor. The second product, Imiquimod, is an immune-response modifier. It is indicated for the topical treatment of actinic keratoses; primary, superficial, basal-cell carcinoma; and external genital and perianal warts. The applicable subheading for Ciclopirox, imported in bulk form, will be 2933.79.0800, Harmonized Tariff Schedule of the United States (HTS), 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 Imiquimod, imported in bulk form, will be 2933.99.7000, HTS, which provides for “Heterocyclic compounds with nitrogen hetero-atom(s) only: Other: Other: Aromatic or modified aromatic: Other: Drugs: Other.” Pursuant to General Note 13, HTS, the rate of duty will be free. This merchandise may be subject to the requirements of the Federal Food, Drug, and Cosmetic Act, which is administered by the U.S. Food and Drug Administration. You may contact them at 5600 Fishers Lane, Rockville, Maryland 20857, telephone number 1-888-443-6332. 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. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division