HS 290375 Dichloropentafluoropropanes (HCFC-225, 225ca, 225cb)

What products does HS 290375 cover?

This subheading covers dichloropentafluoropropanes, specifically identifying isomers such as HCFC-225, HCFC-225ca, and HCFC-225cb. These are halogenated derivatives of acyclic hydrocarbons, containing both chlorine and fluorine atoms, and are precisely defined by their chemical structure as propanes with two chlorine and five fluorine atoms. The WCO Harmonized System Explanatory Notes for Chapter 29, Heading 2903, clarify the scope for halogenated derivatives, and this specific subheading captures these particular isomers due to their distinct chemical composition and environmental significance. Importers should verify the exact chemical name and CAS number against official product specifications to ensure accurate classification under the USITC Harmonized Tariff Schedule (HTSUS) or EU TARIC system.

What falls outside HS 290375?

The following products are excluded from HS 290375: other halogenated derivatives of propanes that do not match the specific dichloropentafluoropropane structure, such as monochloropentafluoropropanes or trichlorotetrafluoropropanes, which would fall under other specific subheadings within 2903. For instance, brominated or iodinated derivatives of propanes, even if otherwise similar, are explicitly excluded as this subheading is limited to chloro-fluoro derivatives. Furthermore, mixtures where dichloropentafluoropropanes are not the essential character, or products that are not chemically defined pure compounds, would typically be classified elsewhere, potentially under mixtures of chemicals or other relevant headings based on their predominant component or function, as per General Interpretative Rule 3(b).

What are common classification mistakes for HS 290375?

A common error is misclassifying other hydrochlorofluorocarbons (HCFCs) or hydrofluorocarbons (HFCs) under HS 290375 simply because they are also halogenated propanes or have similar environmental profiles. For example, HCFC-123 (dichlorotrifluoroethane) or HFC-227ea (heptafluoropropane) are distinct chemical compounds with different structures and are classified under separate, specific subheadings within Heading 2903. Another mistake involves overlooking the "chemically defined pure compound" requirement for Chapter 29, attempting to classify non-isolated isomers or complex mixtures here. Proper application of General Interpretative Rule 1, which dictates classification according to the terms of the headings and any relative section or chapter notes, is crucial to avoid these errors.

How should importers classify products under HS 290375?

The correct procedure for classifying products under HS 290375 involves first confirming the precise chemical identity of the substance, specifically verifying that it is a dichloropentafluoropropane (e.g., HCFC-225, 225ca, or 225cb) through chemical analysis, safety data sheets (SDS), or certificates of analysis. Importers and customs brokers should cross-reference the chemical name and CAS number with the WCO Harmonized System Explanatory Notes for Chapter 29, Heading 2903, and consult the specific national tariff schedules like the USITC HTSUS or EU TARIC for any additional national notes or rulings. If there is any ambiguity, seeking a binding tariff information (BTI) ruling from the relevant customs authority is the most reliable method to ensure compliance and avoid potential penalties.