HS 293629 Other vitamins and their derivatives

What products does HS 293629 cover?

This subheading covers "Other vitamins and their derivatives" not specifically provided for in subheadings 293621 through 293628. This includes a wide array of synthetic and natural organic compounds recognized as vitamins, along with their chemically modified derivatives, provided they retain the characteristic activity of the vitamin. Examples include Vitamin K (phylloquinone, menaquinone), Vitamin B5 (pantothenic acid and its salts like calcium pantothenate), Vitamin B7 (biotin), and Vitamin B9 (folic acid and its salts like calcium folinate), as defined by the World Customs Organization's Harmonized System Explanatory Notes for Heading 2936 and reflected in the USITC Harmonized Tariff Schedule (HTSUS) and EU TARIC. These substances are essential micronutrients for normal metabolic function.

What falls outside HS 293629?

The following products are excluded from HS 293629: provitamins, which are precursors that the body converts into vitamins (e.g., beta-carotene, a provitamin A, is classified under 293690); vitamin preparations put up for retail sale as medicaments or food supplements (these fall under Chapter 30 or 21, respectively, depending on their presentation and intended use); and vitamins mixed with other substances in proportions that alter their fundamental character as a vitamin. For instance, a vitamin B complex preparation in dosage form for therapeutic or prophylactic uses would be classified under Heading 3004, while a vitamin-fortified beverage would be in Chapter 22. Similarly, synthetic hormones, even if structurally similar, are classified under Heading 2937.

What are common classification mistakes for HS 293629?

A common error is misclassifying provitamins or vitamin derivatives that lack vitamin activity under 293629. Importers often overlook the specific definitions within the WCO Explanatory Notes, which clearly distinguish between active vitamins and their precursors or inactive forms. Another frequent mistake involves classifying vitamin preparations in dosage forms under this subheading, rather than under Chapter 30 (Pharmaceutical Products) or Chapter 21 (Miscellaneous Edible Preparations) when they are clearly presented for retail sale as medicaments or food supplements, respectively. This often violates General Interpretative Rule (GRI) 3(a) or 3(b) if the product is a mixture or composite good, or GRI 6 for subheadings, by failing to apply the most specific description. Always consider the product's form, concentration, and primary intended use.

How should importers classify products under HS 293629?

The correct procedure for classifying products under HS 293629 involves a multi-step approach. First, confirm the chemical identity of the substance and verify it is indeed a vitamin or a derivative retaining vitamin activity, referencing official chemical nomenclature and specifications. Second, consult the WCO Harmonized System Explanatory Notes for Heading 2936 to ensure the product is not specifically excluded or more appropriately classified elsewhere, particularly in subheadings 293621 through 293628. Third, review the USITC Harmonized Tariff Schedule (HTSUS) or EU TARIC for any specific legal notes or rulings that might impact classification. Finally, ensure the product is not a preparation for retail sale as a medicament or food supplement, which would necessitate classification in Chapter 30 or 21, respectively. Always retain detailed chemical analysis reports and product specifications for customs verification.