HS 291229 Other

What products does HS 291229 cover?

This subheading covers cyclic aldehydes, other than benzaldehyde (2912.21) and other than those with other oxygen function (2912.29). Specifically, it encompasses a diverse range of cyclic aldehydes that do not possess additional oxygen-containing functional groups, nor are they specifically benzaldehyde. Examples include cinnamaldehyde, which is a cyclic aldehyde but does not have an additional oxygen function, and various other aromatic or alicyclic aldehydes not specified elsewhere in Heading 2912. The scope is defined by the absence of other oxygen functions, distinguishing it from subheadings like 2912.4x, and by not being benzaldehyde, as per the World Customs Organization (WCO) Harmonized System Explanatory Notes and consistent with definitions found in the USITC Harmonized Tariff Schedule of the United States (HTSUS) and the EU TARIC system.

What falls outside HS 291229?

The following products are excluded from HS 291229: benzaldehyde, which is specifically classified under HS 2912.21. Additionally, cyclic aldehydes that possess other oxygen functions, such as hydroxyl groups, ether groups, or ester groups, are excluded and typically fall under HS 2912.4x, for example, vanillin (4-hydroxy-3-methoxybenzaldehyde) would be classified under 2912.42. Aldehyde-alcohols, aldehyde-ethers, aldehyde-phenols, and other aldehydes with other oxygen functions are systematically excluded from 2912.29. Furthermore, non-cyclic aldehydes, such as formaldehyde (2912.11) or acetaldehyde (2912.12), are also outside the scope of this subheading, as it is strictly limited to cyclic aldehydes without additional oxygen functions.

What are common classification mistakes for HS 291229?

A common error is misclassifying cyclic aldehydes with additional oxygen functions under HS 291229, instead of the more specific subheadings under 2912.4x. For instance, classifying vanillin (an aldehyde-phenol) under 291229 instead of 2912.42 is a frequent mistake, failing to apply General Rule of Interpretation (GRI) 6 which mandates classification at the subheading level based on the most specific description. Another mistake involves overlooking the "cyclic" requirement, potentially leading to the erroneous inclusion of acyclic aldehydes. Importers sometimes also confuse derivatives or precursors that are not themselves aldehydes, or misinterpret the "other oxygen function" criterion, leading to incorrect placement of complex organic chemicals that might contain an aldehyde group but also other significant functional groups that dictate a different classification.

How should importers classify products under HS 291229?

The correct procedure for classifying products under HS 291229 involves a rigorous chemical analysis to confirm the presence of a cyclic aldehyde structure and, crucially, the absence of any other oxygen-containing functional groups. Importers and customs brokers should first verify that the product is indeed an aldehyde and that its structure is cyclic. Subsequently, a detailed examination of the molecular structure is required to confirm that no hydroxyl, ether, ester, or other oxygen-bearing functional groups are present, which would direct classification to HS 2912.4x. Consulting the WCO HS Explanatory Notes for Heading 2912 is essential, along with cross-referencing the USITC HTSUS or EU TARIC for specific national interpretations and binding rulings, ensuring compliance with GRI 1 and GRI 6 for accurate and defensible classification.