NCS/ARS/CL/10207

You have applied for the tariff classification of KRONES Colclean FC 2001 1150-kg-IBC. According to the MSDS, the product is a high foaming alkaline cleaning agent with chlorine-based disinfectants for industrial use. Additionally, the attached proforma invoice also shows that the product is being imported in 6 (six) pieces of 1,150 IBC tanks.

ANALYSIS AND CLASSIFICATION

The MSDS and Chemical Analysis report provided state that the product is a mixture made up of the following chemicals producing a fatty amine oxide:

• Sodium hydroxide (NaOH); a strong alkaline compound that aids in breaking down organic matter including fats and proteins.
• Amines, C12-14-alkyldimethyl:  is a Non-ionic fatty amine commonly used as a surface-active product.
• Sodium hypochlorite solution – Oxidizing and bleaching and disinfecting agent.

This organic surfactant forms an emulsion with both hydrophilic (water-loving) and hydrophobic (water-repelling) properties, characteristics that align with the description for ampholytic organic surface-active products other than soap of heading 3402. They are referred to as ampholytic because they possess both anionic and cationic qualities.

Accordingly, and based on the information in the preceding paragraphs, KRONES Colclean FC 2001 is effectively classified under tariff heading 3402.49.90.00 as “Other surface-active preparations, washing or cleaning preparations, not put up for retail sale” at 20% duty rate with 7.5% VAT in the ECOWAS CET 2022 - 2027.

LEGAL FRAMEWORK

GIR 1 and 6

This ruling is being issued under the provisions of Section 24 of the Nigeria Customs Service Act (NCSA) 2023.