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Newly Released CBP HQ Rulings on March 15

The Customs Rulings Online Search System (CROSS) was updated March 15 with the following headquarters rulings (ruling revocations and modifications will be detailed elsewhere in a separate article as they are announced in the Customs Bulletin):

H304802: Affirmation of NY N304363; Classification of Lipacide C8G

Ruling: Lipacide C8G is properly classified under subheading 2924.19.8000 as “Carboxyamide-function compounds; amide-function compounds of carbonic acid: Acyclic amides (including acyclic carbamates) and their derivates; salts thereof: Other: Other.” The underlying NY ruling is affirmed.
Issue: What is the correct classification of Lipacide C8G?
Item: A complex substance registered under the European chemical regulation as “N-(1-oxooctyl)glycine." It is also known as Capryloyl glycine. It is used as an active agent for the manufacture of cosmetics and is an ingredient and not a finished product. The molecular formula is C10H19NO3.
Reason: Subheading note 1 to Chapter 29 establishes that within "any one heading of this chapter, derivatives of a chemical compound … are to be classified in the same subheading as that compound … provided that they are not more specifically covered by any other subheading and there is no residual subheading named 'Other' in the series of subheadings concerned.” Lipacide C8G does not meet the definition of an amide.
Ruling Date: March 14, 2023