Analysis
HTS 3804.00.10 covers lignin sulfonic acid and its salts under heading 3804 (residual lyes from the manufacture of wood pulp, whether or not concentrated, desugared…).
Within this group the rate runs from 3.7% to 3.7%. Compared with 3804.00.50 (residual lyes from the manufacture of wood pulp, whether or not…), which pays 3.7%, a misclassification either way moves the duty by 3.7 percentage points.
The normal trade relations rate here is zero, shared by about 25% of the 179 tariff lines in chapter 38, 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.
The other line in the same group is 3804.00.50 (residual lyes from the manufacture of wood pulp, whether or…, 3.7%).
Goods from countries without normal trade relations pay the column 2 rate of 20% instead of nothing, so origin decides between free entry and a 20% duty.
Census statistics map these goods to NAICS 322110 (Pulp Mills), an industry of 35 US establishments employing 9,609 people. That concordance is how imports of this line are compared with US output.
Neighbouring lines
| Line | Description | General rate |
|---|---|---|
| 3804.00.50 | Residual lyes from the manufacture of wood pulp, whether or not concentrated, desugared or chemically treated, including lignin sulfonates, but excluding tall oil of heading 3803: other | 3.7% |