Palmitic acid, stearic acid, their salts and esters
H312954 · 2021-07-08 — Internal Advice Request; Classification of DT 80 (86.9% palmitic acid content), DT 98 (99.2% palmitic acid content), and DT 100 (45.5% palmitic acid content)
The PNGM Center submitted its request following receipt of a July 28, 2020, request by Grunfeld, Desiderio, Leibowitz, Silverman & Klestadt LLP (“GDLSK”), on behalf of Darby Trading Inc. (“Darby”), that the PNGM Center seek internal advice from our office pursuant to 19 C.F.R. § 177.11(a). In reaching our decision, we gave counsel for Darby the opportunity to meet with us telephonically on May 3, 2021 to provide additional comments. We have also given consideration to the subsequent arguments contained in counsel’s email, dated May 6, 2021, claiming classification of the DT 98 formulation in…
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