NCS/ARS/CL/10276

You have applied for the tariff classification of KRONES HYDROCARE 1902, imported in 250 kg drums.

PRODUCT ANALYSIS

Based on the documents submitted, KRONES Hydrocare 1902 is a clear yellow liquid, a membrane-cleaning preparation used in water-treatment operations. The Material Safety Data Sheet (MSDS) indicates that the product contains the following components:

• Sodium hydroxide (NaOH): ≥ 25.00 – < 50.00 wt%
• 2-Phosphonobutane-1,2,4-tricarboxylic acid (PBTC): < 2.50 wt%

1. Sodium Hydroxide (NaOH): Sodium hydroxide is a strong inorganic alkali, commonly supplied as pellets, flakes, or aqueous solutions (caustic soda). It is highly corrosive to the skin, eyes, and mucous membranes, and reacts readily with many metals and organic materials. At a concentration of 25–50%, NaOH acts as a high-strength alkaline agent which act as a:

• pH adjuster or neutraliser
• Saponifying agent (converts fats/oils into soap)
• Powerful corrosive cleaning/degreasing agent
• Reactive base for various chemical processes

At this concentration, NaOH overwhelmingly determines the product’s alkalinity, function, and hazard profile.

2.         2-Phosphonobutane-1,2,4-tricarboxylic Acid (PBTC): PBTC is an organophosphorus compound widely used in industrial water-treatment formulations as a: Scale inhibitor, Corrosion inhibitor and Chelating/dispersing agent

Even at low levels (low wt%), PBTC effectively binds metal ions such as Ca²⁺, Mg²⁺, and Fe³⁺, preventing the formation of deposits and protecting system components from scale and corrosion—especially in alkaline conditions.

FUNCTIONAL INTERPRETATION OF THE MIXTURE

The composition shows that KRONES Hydrocare 1902 is fundamentally a strong alkaline cleaning and water-treatment preparation, where: Sodium hydroxide provides aggressive cleaning, degreasing, and high alkalinity. And PBTC, though present in small amounts, stabilises the system by preventing scale formation and inhibiting corrosion during use.

In industrial applications:

• As a cleaner/degreaser: NaOH performs the actual cleaning, while PBTC protects equipment from scale/corrosion in high-hardness or recirculating water systems.
• In water-treatment or membrane/boiler cleaning formulations:
  The alkaline environment enhances cleaning efficiency, and PBTC prevents metal-ion precipitation and redeposition on equipment surfaces.

TARIFF CLASSIFICATION

Based on the composition of chemical constituents stated in your documentation, KRONES Hydrocare 1902, is 50% Sodium Hydroxide (Caustic Soda), making it the primary component of the product. Furthermore, Explanatory Notes (A) to tariff heading 2815 - Sodium hydroxide (caustic soda); potassium hydroxide (caustic potash); peroxides of sodium or potassium... described the various form Sodium Hydroxide can assume to classify it under chapter 2815.

Based on the above, the product is effectively classifiable under subheading 28.15.12.00.00 - Sodium hydroxide (caustic soda), In aqueous solution (soda lye or liquid soda) with 5% Rate of Duty and 7.5% VAT in line with ECOWAS CET 2022–2027.

LEGAL JUSTIFICATION

GIR 1 & 6