NCS/ARS/CL/10279

You have applied for the tariff classification of KRONES Colclean FC 3001, a cleaning preparation imported in 1,200 kg Intermediate Bulk Containers (IBC tanks).

 PRODUCT ANALYSIS 

According to documentation KRONES colclean FC 3001 is a concentrated acidic foam cleaner, based on phosphoric acid and a blend of high foaming wetting agents/emulsifiers. It is specially formulated for the removal of water hardness scale and other mineral deposits from food processing equipment and plant.  The product contains the following key components:

1. Phosphoric acid: ≥ 25 – < 50 wt%
2. Isotridecanol, ethoxylated (ethoxylated fatty alcohol): ≥ 10 – < 25 wt%
3. Amines, C12–14 (even numbered) alkyldimethyl, N-oxides (amine oxides): < 5 wt%

This composition shows a mixture dominated by a strong inorganic acid (phosphoric acid) combined with non-ionic and amphoteric surfactants.

FUNCTIONAL ROLE OF EACH COMPONENT

A. Phosphoric Acid (H₃PO₄) — Is a moderately strong inorganic acid commonly used in descaling, rust removal, pH adjustment, and acid cleaning formulations. At 25–50%, it provides significant acidity, enabling the removal of mineral scale, metal oxides, rust, and alkaline deposits. It defines the pH, corrosivity, and primary purpose of the mixture.

 B. Isotridecanol, Ethoxylated - Is a non-ionic surfactant produced by ethoxylation of isotridecanol (a chemical process that adds ethylene oxide to isotridecanol to create a non-ionic surfactant). At 10–25%, it improves wetting, penetration, and grease/soil emulsification. It Reduces surface tension for better contact of the acid with deposits, it helps lift organic soils (grease, oils) during cleaning, it stabilizes the formulation and it enhances rinsability.

C. C12–14 Alkyldimethylamine Oxide (Amine Oxide) — Amphoteric/Weak Cationic Surfactant - Is commonly found in detergents, disinfectants, and cleaners. It is present at < 5%, but highly effective even at low concentrations. It Boosts foam stability and cleaning performance, helps solubilize oily soils, and provides mild antimicrobial properties. 

Combining a strong inorganic acid with non-ionic and amphoteric surfactants, produces an acid-based cleaning/descaling formulation that may likely be used as Acid cleaner, Descaler, Rust remover, Mineral deposit remover, Heavy-duty industrial cleaner etc.

How the components work together:

• Phosphoric acid dissolves mineral scale, metal oxides, rust, limescale, and alkaline residues.
• Ethoxylated isotridecanol enhances wetting, allowing the acid to penetrate scale and soils more efficiently.
• Amine oxide boosts cleaning power by emulsifying organic residues (oils/grease) and stabilizing foam.

The mixture therefore delivers both mineral scale removal (acid action) and organic soil removal (surfactant action) — making it suitable for industrial cleaning applications where mixed soils are present.

Summarily, the mixture is best described as a strong acid-based cleaning/descaling preparation whose performance is dominated by phosphoric acid, supported by surfactants that enhance wetting, penetration, and organic soil removal.

TARIFF CLASSIFICATION

The Explanatory Notes to 3402 - “Organic surface-active agents (other than soap); surface-active preparations, washing preparations (including auxiliary washing preparations) and cleaning preparations..., Notes (II)(C) specifically enumerated the types of cleaning 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.

In line with the above provisions, KRONES Colclean FC 3001 is a formulated preparation consisting primarily of phosphoric acid, combined with non-ionic and amphoteric surfactants. This composition yields an acid-based cleaning and descaling agent suitable for applications such as acid cleaning, scale removal, rust removal, mineral deposit dissolution, and other heavy-duty industrial cleaning operations.”

Accordingly, based on its composition, functional characteristics, and intended application, the product is appropriately classified under subheading 3402900000 - 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