HS 293020 Thiocarbamates and dithiocarbamates

What products does HS 293020 cover?

This subheading covers thiocarbamates and dithiocarbamates, which are organic chemical compounds characterized by the presence of a sulfur atom double-bonded to a carbon atom, which is also bonded to a nitrogen atom and another sulfur or oxygen atom, respectively. These compounds are derivatives of carbamic acid where an oxygen atom is replaced by sulfur. The WCO Harmonized System Explanatory Notes for Heading 2930 specify that this subheading includes both simple and complex derivatives, provided they retain the fundamental thiocarbamate or dithiocarbamate structure. Examples include sodium dimethyldithiocarbamate and zinc dimethyldithiocarbamate, which are often used as fungicides or vulcanization accelerators. The USITC Harmonized Tariff Schedule and EU TARIC further define the scope to include various salts and esters of these compounds.

What falls outside HS 293020?

The following products are excluded from HS 293020: thioureas and their derivatives, which are classified under HS 293090 as "Other organo-sulphur compounds," because they lack the carbamate structure. Similarly, certain pesticides or pharmaceutical products containing a thiocarbamate or dithiocarbamate moiety but formulated as preparations for specific uses (e.g., ready-to-use fungicides or medicaments) are generally excluded and classified under headings such as Chapter 30 (Pharmaceutical Products) or Chapter 38 (Miscellaneous Chemical Products), according to their primary function and composition. For instance, a formulated agricultural fungicide containing a dithiocarbamate as an active ingredient would typically be classified under HS 3808, not HS 293020, as it is no longer a pure, unmixed chemical compound of Heading 2930.

What are common classification mistakes for HS 293020?

A common error is misclassifying formulated products containing thiocarbamates or dithiocarbamates as the pure chemical compound under HS 293020, rather than as a preparation. Importers often overlook General Interpretative Rule (GRI) 3(b), which dictates that mixtures, composite goods, and goods put up in sets for retail sale should be classified by the material or component which gives them their essential character. For example, a fungicide consisting of 75% zinc dimethyldithiocarbamate and 25% inert carriers should be classified under HS 3808. Another mistake is confusing thiocarbamates with thioureas, leading to incorrect classification under HS 293090. Careful structural analysis of the chemical compound is essential to distinguish between these related but distinct chemical families.

How should importers classify products under HS 293020?

The correct procedure for classifying products under HS 293020 involves first verifying the precise chemical name and structure of the compound against official chemical nomenclature. Importers and customs brokers should consult the WCO Harmonized System Explanatory Notes for Chapter 29 and Heading 2930 to confirm the scope of "thiocarbamates and dithiocarbamates." It is crucial to obtain a Certificate of Analysis or a Safety Data Sheet (SDS) from the manufacturer, which typically provides the CAS number and chemical formula, allowing for accurate identification. If the product is a pure, unmixed thiocarbamate or dithiocarbamate, it will fall under HS 293020. However, if it is a mixture, preparation, or formulated product, further analysis under GRI 3 is necessary to determine if it should be classified elsewhere, such as in Chapter 38 for agricultural products or Chapter 30 for pharmaceuticals, based on its intended use and essential character.