Tariff Classification Advance Ruling
S1705 Water Treatment, product number S1705SC


Greg Friedman
Sunbeam Corporation (Canada) Ltd.
20B Hereford Street
Brampton, Ontario  L6Y 0M1

Date of issuance of ruling:

This is in response to your request for an advance ruling on the tariff classification of an S1705 Water Treatment, product number S1705SC. This product is exported from Jarden Neosho, 303 Nelson Avenue, Neosho, MO, 64850, USA.

TRS Number: 270447
Classification Number: 3824.90.00.52
Effective Date:

Product Description

The S1705 Water Treatment is a solution, packaged for retail sale, in a 32 fl. oz. bottle for use as a humidifier water treatment to prolong the life of wick filters and warm mist heating systems by helping to prevent lime and scale build-up.

Analysis and Justification

In your request for a ruling, it was suggested that 3402.20.90.90 is the appropriate tariff classification number for the product. Based on the information provided on the packaging and the MSDS, the S1705 Water Treatment, product number S1705SC, consists of a deliberate mixture of ethylene diamine tetra acetic acid, tetrasodium salt (also known as EDTA) and etidronic acid (also known as HEDPA). The EDTA is a chelating agent, often used to reduce the hardness of the water, and the HEDPA is a scale and corrosion inhibitor.

Heading 38.24 provides for chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included.

Further, Explanatory Note (B) (15) to heading 38.24 indicates that the following products are included in this heading: "Anti-scaling compounds usually based on sodium carbonate, sodium silicate, tannin, etc. These compounds, added to hard water, precipitate most of the dissolved calcium and magnesium salts, thus preventing the formation of calcareous deposits in boilers, the tubes of steam generators and other apparatus through which water circulates."

This product meets the description of goods mentioned in the above Explanatory Note, and therefore meets the terms of heading 38.24 as a chemical product and preparation of the chemical or allied industries not elsewhere specified or included.


Section 10 of the Customs Tariff directs that classification of imported goods shall be determined in accordance with the General Rules for the Interpretation of the Harmonized System. Section 11 of the Customs Tariff states that in interpreting the headings and subheadings, regard shall be had to the World Customs Organization's (WCO) Explanatory Notes to the Harmonized Commodity Description and Coding System.

General Interpretative Rule 1 (GIR 1) directs that titles of Sections, Chapters and sub-Chapters are provided for ease of reference only. For legal purposes, classification shall be determined according to the terms of the heading and any relative Section and Chapter Notes. Similarly, General Interpretative Rule 6 (GIR 6) directs that classification shall be determined according to the terms of those subheadings and any related Subheading Notes.

In accordance with GIR 1 and 6, the S1705 Water Treatment, product number S1705SC is classified in 3824.90.00.52 as an anti-scaling compound.

Legislative/Administrative References

This ruling has been issued under paragraph 43.1(1)(c) of the Customs Act and will be honoured by the CBSA for future importations of the goods specified, provided the material facts and circumstances remain as originally presented; all conditions in the ruling have been met; the ruling has not been modified, revoked, revised, or cancelled; and the Customs Tariff legislation has not changed. Should there be a change in the material facts or circumstances pertaining to the goods, you must notify the CBSA as soon as possible. You may request that the advance ruling be modified or revoked as of the date of the change.

Importers should quote the advance ruling number at the time of importation in either the description field of the B3 entry document or on the Canada Customs Invoice. Exporters or producers should quote the advance ruling number on the Certificate of Origin or commercial invoice accompanying the goods.

Should you disagree with this advance ruling, you may file a dispute notice under subsection 60(2) of the Customs Act within 90 days of the date of issuance. Please see the procedures outlined in Appendix C of the CBSA's Memorandum D11-11-3, Advance Rulings for Tariff Classification.

This advance ruling is considered 'reason to believe' for the purposes of section 32.2 of the Customs Act and the CBSA's Administrative Monetary Penalty System, described in Memorandum D22-1-1.

All Memoranda referenced in this letter may be accessed on the CBSA website.

Consent to the Public Release of the Advance Ruling

As per your consent statement, we will release this advance ruling to the public, in both official languages, in accordance with the procedures described in Memorandum D11-11-3. The ruling will be published on the CBSA website in 30 days.

CBSA Contact

Mark Grant
Manager, Tariff Policy Unit 'B'
Trade Policy Division
Headquarters, Ottawa

File Number


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