h053675- u. s. customsand border protection（h053675——美国customsand边境保护）.doc

HQ H053675 March 25, 2009 DRA-4 OT:RR:CTF: ER H053675 PTM Mr. James W. Brown Danzas AEI Drawback Services 22210 Highland Knolls Drive Katy, Texas 77450 RE: Commercial Interchangeability; 19 U.S.C. § 1313(j)(2); 19 C.F.R § 191.32(c) Dear Mr. Brown: This is in response to your letter, dated February 25, 2009, on behalf of Tricon Energy, Inc. (hereinafter “Tricon”) regarding the commercial interchangeability of imported and domestically purchased methanol. FACTS: Tricon buys and sells petrochemicals, including methanol. Tricon imports methanol for sale and deliver in the United States and purchases domestically made methanol for foreign sale. Methanol is a hydrocarbon, derived from natural gas, composed of carbon, hydrogen and oxygen. Its chemical formula is CH3OH. Methanol is an alcohol and is a colorless, neutral, polar and flammable liquid. Methanol is typically produced using a catalytic process with natural gas and steam as the feedstocks. The natural gas is catalytically reformed to carbon oxides and hydrogen. The resulting synthesis gas mixture is circulated under pressure and moderate temperature in the presence of a metallic catalyst and converted to crude methanol. Crude methanol is distilled to yield commercial chemical grade methanol. Methanol is used as a building block for several chemicals and products. It is also use to make windshield washer antifreeze, fuels, waste water treatment and in biodiesel production. In support of your claim for interchangeability you provided specifications for both the imported and exported methanol. You have also provided CBP forms and shipping documents related to the respective import and export transactions involving Tricon’s methanol products. For the import transaction, you submitted a copy of the Entry Summary (CBP Form 7501) for entry number xxxxx32346-0,