HS 291830 Carboxylic acids with aldehyde or ketone function but without other oxygen function, their anhydrides, halides, peroxides, peroxyacids and their derivatives

What products does HS 291830 cover?

This subheading covers carboxylic acids that possess an aldehyde or ketone function, but critically, lack any other oxygen function beyond those inherent to the carboxylic acid group, aldehyde group, or ketone group. It also includes their anhydrides, halides, peroxides, peroxyacids, and derivatives thereof. Examples include pyruvic acid (2-oxopropanoic acid) and acetoacetic acid (3-oxobutanoic acid), which are alpha-keto acids and beta-keto acids, respectively. The WCO Harmonized System Explanatory Notes for Heading 2918 clarify that this subheading specifically targets compounds where the oxygen is solely present as part of the carboxylic acid, aldehyde, or ketone functional groups, distinguishing them from compounds with additional hydroxyl or ether functions. This definition is consistently applied across the USITC Harmonized Tariff Schedule and the EU TARIC.

What falls outside HS 291830?

The following products are excluded from HS 291830: carboxylic acids with an aldehyde or ketone function that also possess other oxygen functions, such as hydroxyl groups or ether linkages, which would typically fall under other subheadings within Heading 2918 or even other chapters. For instance, gluconic acid, despite having a carboxylic acid and aldehyde function, also contains multiple hydroxyl groups, classifying it under HS 291819 (other carboxylic acids with alcohol function). Similarly, compounds like citric acid, which is a tricarboxylic acid with a hydroxyl group, are classified under HS 291815. The presence of any additional oxygen function beyond the specified aldehyde, ketone, or carboxylic acid groups is the primary determinant for exclusion.

What are common classification mistakes for HS 291830?

A common error is misclassifying carboxylic acids that possess an aldehyde or ketone function but also contain other oxygen functions, such as hydroxyl groups or ether groups, into HS 291830. Importers sometimes overlook the crucial "but without other oxygen function" clause, leading to incorrect assignments. For example, compounds like tartaric acid, which has two carboxylic acid groups and two hydroxyl groups, are frequently mistaken for this subheading but correctly belong to HS 291813. This mistake often stems from a superficial review of the chemical structure rather than a detailed analysis of all functional groups present, directly violating General Interpretative Rule (GRI) 1, which mandates classification according to the terms of the headings and any relative section or chapter notes.

How should importers classify products under HS 291830?

The correct procedure for classifying products under HS 291830 involves a meticulous review of the chemical structure to confirm the presence of a carboxylic acid group, an aldehyde or ketone group, and crucially, the absence of any other oxygen-containing functional groups (e.g., hydroxyl, ether, ester, peroxide, peroxyacid, or hydroperoxide groups) beyond those explicitly permitted. Importers and customs brokers should obtain a detailed Certificate of Analysis (CoA) or chemical specification sheet for the product. This documentation must clearly identify all functional groups. Cross-referencing the chemical name and CAS number with the WCO Harmonized System Explanatory Notes for Heading 2918, the USITC Harmonized Tariff Schedule, and the EU TARIC is essential to ensure accurate classification and compliance, preventing potential delays or penalties.