HS 292144 Diphenylamine and its derivatives; salts thereof

What products does HS 292144 cover?

This subheading covers diphenylamine and its derivatives, as well as their respective salts. Diphenylamine (N-phenylaniline) is an organic compound with the chemical formula (C6H5)2NH, primarily used as an antioxidant in various industries. Derivatives refer to compounds structurally related to diphenylamine, where one or more hydrogen atoms have been replaced by other functional groups, provided they retain the fundamental chemical characteristics of an aromatic amine. This classification is consistent with the Explanatory Notes to the Harmonized System, specifically Heading 2921, which covers "Amine-function compounds." Official tariff schedules, such as the USITC Harmonized Tariff Schedule of the United States (HTSUS) and the EU TARIC, define this subheading precisely to include these specific chemical entities.

What falls outside HS 292144?

The following products are excluded from HS 292144: compounds that are not diphenylamine or its direct derivatives, or their salts. For instance, primary aromatic monoamines (e.g., aniline, toluidines) are classified under HS 2921.41 or 2921.42, while aromatic polyamines (e.g., phenylenediamines) fall under HS 2921.51 or 2921.59. Additionally, nitrogen-function compounds that are not primarily amine-function, such as amides (Chapter 29, Subheading 2924) or imides, are excluded. Mixtures containing diphenylamine but where diphenylamine is not the predominant component or where the mixture forms a preparation for a specific use (e.g., an insecticide preparation) would typically be classified elsewhere, potentially in Chapter 38 or 39, depending on their composition and intended use.

What are common classification mistakes for HS 292144?

A common error is misclassifying complex mixtures or preparations containing diphenylamine as pure diphenylamine or its derivatives under HS 292144. According to General Interpretative Rule (GRI) 3(b), mixtures are classified by the material or component which gives them their essential character. If diphenylamine is merely an ingredient in an antioxidant blend, a pesticide formulation, or a rubber processing chemical, the product's essential character may be determined by other components or its function, leading to classification in Chapter 38 or even Chapter 39 if it's a plastic material. Another mistake is failing to correctly identify whether a compound is indeed a "derivative" of diphenylamine, necessitating a thorough understanding of organic chemistry and the specific chemical structure to ensure it retains the core amine functionality as defined by Heading 2921.

How should importers classify products under HS 292144?

The correct procedure for classifying products under HS 292144 involves several critical steps for importers and customs brokers. First, precisely identify the chemical name and structure of the product, including any substituents, to confirm it is diphenylamine, a direct derivative, or a salt thereof. Obtain the Chemical Abstracts Service (CAS) number and Safety Data Sheet (SDS) for verification. Second, consult the WCO Harmonized System Explanatory Notes for Chapter 29, Heading 2921, to understand the scope of "amine-function compounds" and "derivatives." Third, cross-reference with the specific national tariff schedule (e.g., HTSUS, EU TARIC, UK Trade Tariff) to ensure the product description aligns. If the product is a mixture, apply General Interpretative Rules (GRI) 1 and 3(b) to determine if diphenylamine or its derivative imparts the essential character. If uncertainty persists, consider requesting a binding ruling from the relevant customs authority to ensure compliance and avoid potential penalties.