The tariff classification of Lubrizol SulfrZol® 54

N147285 March 11, 2011 CLA-2-38:OT:RR:NC:2:235 CATEGORY: Classification TARIFF NO.: 3811.90.0000 Mr. Rick Van Arnam Barnes Richardson & Colburn 475 Park Avenue South New York, NY 10016 RE: The tariff classification of Lubrizol SulfrZol® 54 Dear Mr. Van Arnam: In your letter dated October 19, 2010, you requested a tariff classification ruling on behalf of your client Lubrizol Corporation. Our office requested additional information, including a sample for analysis. The additional information and sample was received on February 9, 2011 and forwarded to the Customs and Border Protection Laboratory for analysis. You described the instant product as an olefin sulfide in liquid form. Per your follow up letter the olefin sulfide in the product is a di-tert butyl polysulfide. You also state that the product consists of varying length sulfur chains bounded by t-butyl groups. The product functions as an upstream fuel additive that is added to the crude to retard catalyst coking, and to allow the crude to move through the refinery at an increased rate. Per your request we will not include the ingredients, and CAS numbers in the published ruling. The Customs and Border Protection Laboratory confirms that the product is a mixture of sulfur containing organo-inorganic compounds. It is an anticorrosive additive for crude oil. The applicable subheading for the Lubrizol SulfrZol® 54 will be 3811.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: “Antiknock preparations, oxidation inhibitors, gum inhibitors, viscosity improvers, anti-corrosive preparations and other prepared additives, for mineral oils (including gasoline) or for other liquids used for the same purposes as mineral oils”. The general 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