Analysis
HTS 2916.39.17 covers 2,2-Dichlorophenylacetic acid, ethyl ester; andm-Toluic acid under heading 2916 (unsaturated acyclic monocarboxylic acids, cyclic monocarboxylic acids, their anhydrides…).
Within this group the rate runs from duty-free to 6.5%. Compared with 2916.39.79 (other: other), which pays 6.5%, a misclassification either way moves the duty by 6.5 percentage points.
The normal trade relations rate here is zero, shared by about 26% of the 1050 tariff lines in chapter 29, a useful check when a neighbouring dutiable line is a candidate. Free here means free of the base duty only: origin-specific Chapter 99 duties such as Section 301 can still be owed.
Census statistics map these goods to NAICS 325199 (All Other Basic Organic Chemical Manufacturing), an industry of 894 US establishments employing 77,304 people. That concordance is how imports of this line are compared with US output.
Every edition we compared, from Jan 2023 to Oct 2026 (Rev. 22), shows the same general rate of Free.
Neighbouring lines
| Line | Description | General rate |
|---|---|---|
| 2916.39.03 | Benzoic anhydride;tert-Butyl peroxybenzoate;p-Nitrobenzoyl chloride; 2-Nitro-m-toluic acid; and 3-Nitro-o-toluic acid | 6.5% |
| 2916.39.04 | m-Chloroperoxybenzoic acid; andp-Sulfobenzoic acid, potassium salt | Free |
| 2916.39.06 | Other: cinnamic acid | 6.5% |
| 2916.39.08 | 4-Chloro-3-nitrobenzoic acid | 6.5% |
| 2916.39.12 | 4-Chloro-3,5-dinitrobenzoic acid and its esters | 6.5% |
| 2916.39.15 | Other: ibuprofen | 6.5% |
| 2916.39.16 | 4-Chlorobenzoic acid | 6.5% |
| 2916.39.21 | Odoriferous or flavoring compounds | 6.5% |
| 2916.39.46 | Products described in additional U.S. note 3 to section VI | 6.5% |
| 2916.39.77 | Esters of phenylacetic acid | Free |
| 2916.39.79 | Other: other | 6.5% |