NCS/ARS/CL/10274

You have applied for the tariff classification of KRONES Colclean FC 5001, a cleaning preparation imported in 1000 kg and 1200 kg Intermediate Bulk Containers (IBC tanks).

PRODUCT ANALYSIS

According to the Material Safety Data Sheet (MSDS) submitted, KRONES Colclean FC 5001 is a cleaning agent composed of the following constituents:

1. Sulfamic Acid (Sulphamic Acid) – ≥10 and <25% by weight (wt%)
2. 1-Propanaminium, 3-amino-N-(carboxymethyl)-N,N-dimethyl-, N-(C8–18 and C18-unsaturated acyl) derivatives, hydroxides, inner salts – ≥5 and <10% by weight (wt%)
3. Amines, C12–14 (even-numbered)-alkyldimethyl, N-oxides – <5% by weight (wt%)

COMPONENT DESCRIPTIONS

1. Sulfamic Acid (Sulphamic Acid) is a white crystalline solid, commonly used as an acidic descaling and cleaning agent. It effectively removes protein residues, milk stone, mineral deposits, and hard water scale, especially in food and beverage processing equipment.

2. 1-Propanaminium, 3-amino-N-(carboxymethyl)-N,N-dimethyl-, N-(C8–18 and C18-unsaturated acyl) derivatives, hydroxides, inner salts: This compound is a betaine derivative, known commercially as Cocamidopropyl Betaine, an amphoteric surfactant that can act as both an acid and a base.

• It contains an ammonium group on a three-carbon chain and a carboxymethyl group (-CH₂COOH) that gives it zwitterionic (a molecule that contains equal number of positively and negatively charged functional group) properties.
• The C8–18 fatty acid chains, derived from natural oils such as coconut or palm oil, improve its cleaning and foaming performance.
• The hydroxide/inner salt enhances solubility and stability over a wide pH range.

This surfactant is mild, biodegradable, and stable, making it suitable for industrial, household, and personal care formulations as a foaming agent, mild detergent, or conditioning agent.

3. Amines, C12–14 (even-numbered)-alkyldimethyl, N-oxides: These are fatty amine oxides, derived from natural fatty alcohols (C12–C14). The molecule consists of:

• Two methyl groups on the nitrogen atom;
• A C12–C14 alkyl chain providing cleaning and foaming ability; and
• An oxygen atom bonded to nitrogen (N-oxide), forming a stable and mild surfactant.

This ingredient acts as non-ionic to amphoteric surfactant, meaning it can be neutral or pH-dependent, and is valued for its mild cleaning, foaming, and emulsifying properties. It also provides antimicrobial activity, improving hygiene and disinfection performance in cleaning applications.

In summary KRONES Colclean FC 5001 is a multi-component acidic cleaning preparation containing:

• Sulfamic acid – an acidic descaling agent;
• Cocamidopropyl betaine – an amphoteric surfactant for mild cleaning and foaming; and
• C12–14 alkyldimethylamine oxide – a non-ionic/amphoteric surfactant, (chemical molecules that interact differently with water, typically used as surfactants in products like detergents and shampoos) that enhances foam stability and cleaning efficiency.

The formulation combines acidic and surfactant properties, indicating that the product is designed for industrial or food-grade cleaning and descaling applications, particularly for the removal of organic and mineral residues from processing systems and equipment.

TARIFF CLASSIFICATION

In line with the above analysis, reference is made to the Explanatory Notes to Heading 34.02 which covers “Organic surface-active agents (other than soap); surface-active preparations, washing preparations (including auxiliary washing preparations) and cleaning preparations, whether or not containing soap, other than those of heading 34.01.” 

Under Note (II)(C) of this heading, the Explanatory Notes specifically enumerated the types of preparations that are classifiable under Heading 34.02. These include cleaning or washing preparations, detergent compositions, and surface-active mixtures or solutions that contain one or more organic surface-active agents capable, in aqueous solution, of reducing surface tension, forming a stable foam, or emulsifying or dispersing oily matter. Such products are used for cleaning, washing, degreasing, and similar purposes in both domestic and industrial applications.

Given that KRONES Colclean FC 5001 contains active constituents such as amphoteric and non-ionic surfactants (Cocamidopropyl Betaine and C12–14 Alkyldimethylamine Oxide) together with Sulfamic Acid (a descaling and cleaning component), the product meets the characteristics outlined in Note (II)(C). It functions primarily as a surface-active cleaning preparation designed for removing organic and mineral deposits.

Accordingly, based on its composition, function, and application, as indicated in your supporting documents, the product is effectively classified under subheading 34.02.90.00.00 - Other organic surface-active agents, whether or not put up for retail sale at 20% Rate of Duty and 7.5% VAT in line with the ECOWAS C.E.T 2022 – 2027.

LEGAL FRAMEWORK

GIR 1 & 6