HS 291521 Acetic acid and its salts; acetic anhydride

What products does HS 291521 cover?

This subheading covers acetic acid, which is a carboxylic acid with the chemical formula CH₃COOH, and its various salts, as well as acetic anhydride. Acetic acid is a fundamental organic chemical used extensively in the production of vinyl acetate monomer, purified terephthalic acid (PTA), and various esters. Its salts include compounds like sodium acetate and potassium acetate. Acetic anhydride, with the formula (CH₃CO)₂O, is the acid anhydride of acetic acid, primarily used in the production of cellulose acetate and as a reagent in organic synthesis. This classification is consistent with the World Customs Organization (WCO) Harmonized System Nomenclature and definitions found in the USITC Harmonized Tariff Schedule (HTS) and the EU TARIC system.

What falls outside HS 291521?

The following products are excluded from HS 291521: esters of acetic acid, such as ethyl acetate or butyl acetate, which are classified under subheading 2915.39. Additionally, preparations containing acetic acid but not consisting solely of the pure chemical or its salts/anhydride, such as vinegar (which is a dilute solution of acetic acid and other components), are excluded and typically fall under Chapter 22. Similarly, pharmaceutical preparations where acetic acid is an active ingredient but presented in a formulated dosage form would be classified under Chapter 30, not as bulk chemical. Polymers derived from acetic acid, like polyvinyl acetate, are classified in Chapter 39.

What are common classification mistakes for HS 291521?

A common error is misclassifying derivatives or mixtures containing acetic acid rather than the pure chemical, its salts, or anhydride. For instance, classifying vinyl acetate monomer (VAM) under 291521 instead of its correct subheading 2915.32 is a frequent mistake, as VAM is an ester of acetic acid, not acetic acid itself or one of its simple salts. Another error involves classifying dilute solutions of acetic acid intended for specific uses, like cleaning solutions, under this subheading when they should be classified as preparations elsewhere in the tariff. Proper application of General Interpretative Rule (GRI) 1, which states that classification is determined according to the terms of the headings and any relative section or chapter notes, is crucial to avoid such errors.

How should importers classify products under HS 291521?

The correct procedure for classifying products under HS 291521 involves first confirming the chemical identity of the imported substance. Importers and customs brokers must verify that the product is indeed acetic acid, an acetic acid salt (e.g., sodium acetate), or acetic anhydride, and not a derivative, ester, or mixture. This often requires reviewing the Certificate of Analysis (CoA) or Safety Data Sheet (SDS) to confirm the chemical name, CAS number, and purity. If the product is a pure chemical matching the description, then classification under 291521 is appropriate. If it is a mixture or a derivative, further analysis of Chapter 29 notes and other relevant chapters (e.g., Chapter 22 for vinegar, Chapter 30 for pharmaceuticals) is necessary to determine the correct alternative classification.