Analysis
HTS 2918.29.22 covers p-Hydroxybenzoic 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 2918.29.39 (4,4-Bis(4-hydroxyphenyl) pentanoic acid; and 3,5,6-Trichlorosalicylic…), 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 12 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 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.
Neighbouring lines
| Line | Description | General rate |
|---|---|---|
| 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% |
| 2918.29.25 | 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% |