h062357- u. s. customsand border protection（h062357——美国customsand边境保护）.doc

HQ H062357 August 24, 2009 DRA-4 OT:RR:CTF:ER H062357 PTM Mr. James W. Brown Danzas AEI Drawback Services 2210 Highland Knolles Drive Katy, TX 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 May 26, 2009 on behalf of Lyondell Chemical Company (hereinafter “Lyondell”) regarding the commercial interchangeability of Tripropylene glycol methyl ether, also known as ARCOSOLV? TPM. FACTS: ARCOSOLV? TPM is a colorless, combustible liquid with low toxicity. It has very little odor and is completely soluble in water. It has excellent solvency for many polar and non-polar substances.? ARCOSOLV? TPM is a good substitute for slow evaporating ethylene glycol (E- series) ethers. ARCOSOLV? TPM is used in coatings, cleaners, wax strippers as well as in agricultural, electronic, ink, textile and adhesive products. Lyondell is engaged in the manufacture, import, purchase and resale of ARCOSOLV? TPM. The substituted merchandise is produced in the United States by Lyondell at its plant in Pasadena, Texas. Lyondell also imports ARCOSOLV? TPM to maintain inventory supplies and ensure its ability to meet customer demands. Lyondell is both the importer and exporter of record for the ARCOSOLV? TPM. All U.S. importations of ARCOSOLV? TPM by Lyondell are discharged and commingled with U.S. domestically produced product in Lyondell’s dedicated shore tanks at the Stolt Terminal Deer Park, Port of Houston, Texas. In support of your claim for interchangeability, you provided specifications for both the imported and exported ARCOSOLV? TPM . You have also provided CBP forms and shipping documents related to the respective import and export transactions involving Lyondell’s ARCOSOLV? TPM products. For the import entry, you submitted an entry summary (CBP form 7501) for entry no. 035XXXX-9, dated October 23, 2006, which describes the imported merchandise as “ARCOSOLV TPM.”