HS 290715 Naphthols and their salts

What products does HS 290715 cover?

This subheading covers naphthols and their salts, which are specific types of phenols derived from naphthalene. Naphthols are aromatic organic compounds containing a hydroxyl group (-OH) attached to a naphthalene ring. The two primary isomers are 1-naphthol (alpha-naphthol) and 2-naphthol (beta-naphthol), both of which are included here, along with their respective salts. This classification aligns with the World Customs Organization's Harmonized System Nomenclature and is consistently applied across national tariffs such as the USITC Harmonized Tariff Schedule (HTSUS) and the EU TARIC system, encompassing both pure forms and mixtures of these specific chemical compounds.

What falls outside HS 290715?

The following products are excluded from HS 290715: Naphthols that have been chemically modified beyond simple salt formation, such as naphthol derivatives containing additional functional groups (e.g., sulfonic acid groups, carboxylic acid groups), would typically be classified under other subheadings within Chapter 29, often under more specific chemical descriptions. For instance, naphthol sulfonic acids and their salts are classified under 2908. Similarly, products where naphthols are merely components of a larger mixture or preparation, and not the primary chemical for classification purposes, would fall elsewhere, depending on the nature of the preparation, such as under Chapter 38 for miscellaneous chemical products or Chapter 32 for dyes.

What are common classification mistakes for HS 290715?

A common error is misclassifying naphthol derivatives that contain additional functional groups beyond the hydroxyl group and its salt. Importers sometimes incorrectly assume that any compound containing a naphthol structure belongs to 290715, overlooking the specificity of the subheading. For example, naphthol sulfonic acids are frequently misclassified here instead of 2908. This mistake often arises from a failure to apply General Interpretative Rule (GRI) 1, which dictates that classification is determined according to the terms of the headings and any relative section or chapter notes, and GRI 6, which extends this principle to subheadings, requiring the most specific description to take precedence. Accurate chemical identification is crucial to avoid such errors.

How should importers classify products under HS 290715?

The correct procedure for classifying products under HS 290715 involves a thorough review of the chemical composition and structure. Importers and customs brokers should first obtain a detailed Certificate of Analysis (CoA) or Safety Data Sheet (SDS) for the product, clearly identifying it as 1-naphthol, 2-naphthol, or their respective salts. Verify that no additional functional groups are present that would lead to classification under a more specific subheading within Chapter 29, such as those for sulfonic acids (2908) or other derivatives. Consult the WCO Explanatory Notes for Heading 2907 and cross-reference with the USITC HTSUS or EU TARIC for any specific national rulings or interpretations. When in doubt, consider requesting a binding ruling from the relevant customs authority to ensure compliance and avoid potential penalties.