NCS/ARS/CL/10189

INTRODUCTION
You requested a tariff classification ruling for a product: KRONES Coclean FC 1005 to be imported in six (6) 1300-kilogram Intermediate Bulk Containers (IBC). 

DESCRIPTION OF THE PRODUCT
According to your MSDS and supporting documents, the product is an alkaline smoking chamber cleaner for the food industry based on sodium and potassium hydroxide. It is also suitable for high water hardness and particularly applicable to the cleaning of heavily encrusted residues of grease and proteins as they are typical for smoking chambers. 

ANALYSIS AND TARIFF CLASSIFICATION
The attached documents show that the elements that make KRONES Coclean FC 1005 are 50% Sodium Hydroxide, 10% Potassium Hydroxide, 2.5% Hexyl D-glucoside, and 2.5% Etidronic acid. The major components by volume—sodium hydroxide (caustic soda) and potassium hydroxide contribute to the high pH of the cleaner. 

The product suits the description provided in Explanatory Note 3402 (C) (ii) of degreasing or cleaning preparations, used, e.g., in dairies or breweries, and with a basis of alkaline substances such as sodium carbonate or caustic soda, or solvents and emulsifiers.

Based on the foregoing, Krones Coclean FC 1005 imported in 1300Kg IBCs is effectively classified in tariff heading 3402: “Organic surface-active agents (other than soap);” subheading 3402.90.00.00 “other cleaning preparations whether or not containing soap…" at 20% duty rate with 7.5% VAT in the ECOWAS CET 2022 - 2027.

LEGAL FRAMEWORK AND JUSTIFICATION
GIR 1 and 6