NCS/ARS/CL/10275

You have applied for the tariff classification of KRONES Colclean FC 1001, a cleaning preparation imported in 1000 kg Intermediate Bulk Containers (IBC tanks).

PRODUCT ANALYSIS

According to the Material Safety Data Sheet (MSDS) submitted, KRONES Colclean FC 1001 is a clear, colourless liquid; a multi-component cleaning compound comprising the following constituents:

1.           Sodium Hydroxide (NaOH): - Commonly known as caustic soda or lye, is a strong alkaline substance used as a pH adjuster and cleaning agent. It breaks down organic matter such as fats and grease, converting them into water-soluble substances through a process known as saponification. Though it is widely used in industrial cleaners, degreasers, and drain-cleaning products, it corrosive in nature and requires controlled use in formulations.

2.           Propan-2-ol (Isopropyl Alcohol): - Also known as isopropanol or rubbing alcohol. It functions primarily as a solvent and disinfectant. It dissolves oils, greases, and other organic residues that water alone cannot remove. Due to its rapid evaporation rate and antimicrobial properties, it enhances drying and sanitation in surface cleaners, glass cleaners, and sanitizing products.

3.           Amines, C12–14 (even-numbered)-alkyldimethyl, N-oxides: Commonly referred to as C12–14 Amine Oxides, this ingredient is non-ionic to amphoteric surfactant. It acts as a cleaning, foaming, and wetting agent, facilitating the mixing of water with oily or greasy soils by reducing surface tension. Amine oxides are biodegradable, mild, and foam-stabilizing, and they also exhibit mild antimicrobial activity, enhancing hygiene performance. They are widely used in household and industrial cleaners, dishwashing liquids, and personal care products.

4.           Alcohol, C12–14, ethoxylated, sulfates, sodium: Commonly known as Sodium Lauryl Ether Sulfate (SLES) or Sodium C12–14 Alkyl Ether Sulfate. This is an anionic surfactant — a powerful detergent and foaming agent.
It removes grease, oils, and particulate soils effectively and works synergistically with amphoteric surfactants (such as amine oxides) to enhance foam stability and cleaning performance. SLES is commonly used in liquid soaps, detergents, shampoos, and industrial cleaning formulations.

Functional Summary of Constituents

The combination of Strong alkaline agent (Sodium Hydroxide), Solvent cleaning ingredient (Propan-2-ol), Foaming and emulsifying surfactants (SLES and Amine Oxide), makes the product high in detergency, foam stability, and effective in removal of organic and oily residues.

According to your supporting document and analysis above, KRONES Colclean FC 1001 is an alkaline surface-active cleaning preparation, formulated for industrial and food-processing equipment cleaning, hard-surface degreasing, and similar sanitation applications.

TARIFF CLASSIFICATION 

In line with the above, and in pursuant to the Explanatory Notes to Heading 34.02 – Organic surface-active agents (other than soap); surface-active preparations, washing preparations..., Note (C) to heading 3402, includes preparations of Acid or alkaline cleaners specially formulated for cleaning sanitary ware, frying-pans, etc.; and 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.

Given the above, KRONES Colclean FC 1001 is an Alkaline formation is effectively classified under subheading 3402.39.90.00 – Other, Anionic organic surface-active Agent with 20% Rate of Duty and 7.5% VAT in line with ECOWAS CET 2022–2027.

LEGAL JUSTIFICATION

GIR 1 & 6