Analysis
HTS 2918.22.50 covers salts and esters of O-acetylsalicylic acid under heading 2918 (carboxylic acids with additional oxygen function and their anhydrides, halides, peroxides…).
Within this group the rate runs from duty-free to 6.5%. Compared with 2918.30.15 (2-Chloro-4,5-difluoro-ß-oxobenzenepropanoic acid, ethyl ester; and…), which pays duty-free, a misclassification either way moves the duty by 6.5 percentage points.
The general duty rate is 6.5% of the customs value, which is above most the rates in chapter 29 (83rd percentile of 1050 lines with an ad valorem rate). On a shipment valued at $10,000 that is $650 in duty before any Chapter 99 additions or preference claims.
Goods that qualify under GSP, the Australia FTA, the Bahrain FTA, the Chile FTA, the Colombia TPA, and 13 others can enter duty-free instead of paying 6.5%. It is also eligible under GSP, the developing-country programme, which Congress has to renew; check whether GSP is in force on the entry date.
Census statistics map these goods to NAICS 325412 (Pharmaceutical Preparation Manufacturing), an industry of 1,436 US establishments employing 170,029 people. That concordance is how imports of this line are compared with US output.
Neighbouring lines
| Line | Description | General rate |
|---|---|---|
| 2918.11.10 | Lactic acid, its salts and esters: lactic acid | 5.1% |
| 2918.11.51 | Lactic acid, its salts and esters: other | 3.4% |
| 2918.12.00 | Carboxylic acids with alcohol function but without other oxygen function, their anhydrides, halides, peroxides, peroxyacids and their derivatives: tartaric acid | Free |
| 2918.13.10 | Potassium antimony tartrate (Tartar emetic) | Free |
| 2918.13.20 | Potassium bitartrate (Cream of tartar) | Free |
| 2918.13.30 | Potassium sodium tartrate (Rochelle salts) | Free |
| 2918.13.50 | Salts and esters of tartaric acid: other | 4.4% |
| 2918.14.00 | Carboxylic acids with alcohol function but without other oxygen function, their anhydrides, halides, peroxides, peroxyacids and their derivatives: citric acid | 6% |
| 2918.15.10 | Salts and esters of citric acid: sodium citrate | 6.5% |
| 2918.15.50 | Salts and esters of citric acid: other | 3.7% |
| 2918.16.10 | Gluconic acid, its salts and esters: gluconic acid | 6% |
| 2918.16.50 | Gluconic acid, its salts and esters: other | 3.7% |
| 2918.17.00 | 2,2-Diphenyl-2-hydroxyacetic acid (benzilic acid) | 5.8% |
| 2918.18.00 | Chlorobenzilate (ISO) | 6.5% |
| 2918.19.11 | Benzilic acid, methyl ester | 5.8% |
| 2918.19.12 | Phenylglycolic acid (Mandelic acid), its salts and esters: mandelic acid | Free |
| 2918.19.15 | Phenylglycolic acid (Mandelic acid), its salts and esters: other | 6.5% |
| 2918.19.20 | Products described in additional U.S. note 3 to section VI | 6.5% |
| 2918.19.31 | Other: other | 6.5% |
| 2918.19.60 | Other: malic acid | 4% |
| 2918.19.90 | Other: other | 4% |
| 2918.21.10 | Suitable for medicinal use | 6.5% |
| 2918.21.50 | Salicylic acid and its salts: other | 6.5% |
| 2918.22.10 | O-Acetylsalicylic acid (Aspirin) | 6.5% |
| 2918.23.10 | Salol (Phenyl salicylate) suitable for medicinal use | 6.5% |
| 2918.23.20 | Odoriferous or flavoring compounds | 6.5% |
| 2918.23.30 | Products described in additional U.S. note 3 to section VI | 6.5% |
| 2918.23.50 | Other: other | 6.5% |
| 2918.29.04 | 2,3-Cresotic acid; 2-Hydroxybenzoic acid, calcium salt; 1-Hydroxy-2-naphthoic acid; 2-Hydroxy-1-naphthoic acid; 1-Hydroxy-2-naphthoic acid, phenyl ester;α-Resorcylic acid;γ-Resorcylic acid; and 5-Sulfosalicylic acid | 5.8% |
| 2918.29.06 | 1,6-Hexanediol bis(3,5-dibutyl-4-hydroxyphenyl)propionate) | 5.8% |
| 2918.29.08 | m-Hydroxybenzoic acid | Free |
| 2918.29.20 | Gentisic acid; and Hydroxycinnamic acid and its salts | 6.5% |
| 2918.29.22 | p-Hydroxybenzoic acid | 6.5% |
| 2918.29.25 | 3-Hydroxy-2-naphthoic acid | 6.5% |
| 2918.29.30 | Other: gallic acid | 1% |
| 2918.29.39 | 4,4-Bis(4-hydroxyphenyl) pentanoic acid; and 3,5,6-Trichlorosalicylic acid | Free |
| 2918.29.65 | Products described in additional U.S. note 3 to section VI | 6.5% |
| 2918.29.75 | Other: other | 6.5% |
| 2918.30.10 | 1-Formylphenylacetic acid, methyl ester | 5.8% |
| 2918.30.15 | 2-Chloro-4,5-difluoro-ß-oxobenzenepropanoic acid, ethyl ester; and Ethyl 2-keto-4-phenylbutanoate | Free |