The tariff classification of Sodium Lauroyl Glutamate

N067843 October 23, 2009 CLA-2-29:OT:RR:NC:2:235 CATEGORY: Classification TARIFF NO.: 2924.19.8000 Ms. Maylynn Ha New Century Customs Broker 8780 Jade LN Rosemead, CA 91770 RE: The tariff classification of Sodium Lauroyl Glutamate Dear Ms. Ha: In your letter dated July 06, 2009, you requested a tariff classification ruling on behalf of Techno Food Ingredients USA, Inc. The subject product, Sodium Lauroyl Glutamate (CAS # 29923-31-7) is also known as L-Glutamic acid, N-(1-oxododecyl)-, monosodium salt. In your letter, you state that your client believes the instant product should be classified as a surfactant in Heading 3402. However, we disagree as the chemical structure of the product was determined by the Customs and Border Protection Laboratory to be a sodium salt of a non-aromatic acyclic carboxyamide function compound and not as a surfactant. Analysis performed at the Customs and Border Protection Laboratory confirms that the product does not meet the definition of a surface active agent for classification purposes. The applicable subheading for Sodium Lauroyl Glutamate will be 2924.19.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Carboxyamide-function compounds; amide-function compounds of carbonic acid: Acyclic amides (including acyclic carbamates) and their derivatives; salts thereof: Other: Other.” The rate of duty will be 6.5 percent ad valorem. 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. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division