HS 293220 Lactones

What products does HS 293220 cover?

This subheading covers lactones, which are cyclic esters formed from hydroxy carboxylic acids, characterized by an ester linkage within a ring structure. The World Customs Organization (WCO) Harmonized System Explanatory Notes for Heading 2932 specifically include lactones, which are internal esters of hydroxy acids. Examples include gamma-butyrolactone, delta-valerolactone, and epsilon-caprolactone. These compounds are widely used as chemical intermediates in the production of polymers, pharmaceuticals, and fragrances. The scope is precisely defined by the chemical structure, requiring both a cyclic form and an ester functional group within that ring, as per the USITC Harmonized Tariff Schedule (HTS) and EU TARIC definitions for this subheading.

What falls outside HS 293220?

The following products are excluded from HS 293220: cyclic ethers (e.g., tetrahydrofuran, dioxane) which lack the ester functional group, even though they are heterocyclic oxygen compounds. Also excluded are non-cyclic esters of hydroxy acids, which would typically fall under Heading 2918 or other relevant ester headings, as they do not possess the defining lactone ring structure. Furthermore, complex heterocyclic compounds with oxygen that are not lactones, such as certain antibiotics or vitamins, would be classified under other specific headings within Chapter 29 or Chapter 30, depending on their chemical nature and intended use. For instance, coumarin, while a lactone, has its own specific subheading 293220.10, but other complex oxygen heterocycles are distinct.

What are common classification mistakes for HS 293220?

A common error is misclassifying other cyclic oxygen compounds as lactones when they lack the essential ester linkage within the ring, such as cyclic ethers or anhydrides. Another frequent mistake involves overlooking specific subheadings for certain well-known lactones, such as coumarin (2932.20.10) or phenolphthalein (2932.20.20), and instead classifying them under the general "Other lactones" (2932.20.50). This often violates General Interpretative Rule (GRI) 6, which mandates classification at the most specific subheading. Importers sometimes also confuse lactones with non-cyclic esters of hydroxy acids, which are classified elsewhere, leading to incorrect duty rates and potential compliance issues due to a misunderstanding of the chemical definition.

How should importers classify products under HS 293220?

The correct procedure for classifying products under HS 293220 involves a thorough review of the chemical structure to confirm the presence of a cyclic ester (lactone) functional group. Importers and customs brokers should first consult the WCO HS Explanatory Notes for Heading 2932 to understand the precise scope. Next, they must check the specific national tariff schedule (e.g., USITC HTS, EU TARIC, UK Trade Tariff) for any specific subheadings for known lactones (e.g., coumarin, phenolphthalein). If no specific subheading exists, the product would fall under the "Other lactones" residual subheading. Always obtain a Certificate of Analysis or a Safety Data Sheet (SDS) to verify the chemical name and structure, ensuring accurate classification and compliance with GRI 1 and GRI 6.