SUPPLEMENTARY INFORMATION:
Request To Add Substance to the List
(a)
Overview.
A petition was filed pursuant to Rev. Proc. 2022-26 (2022-29 I.R.B. 90),
as modified by
Rev. Proc. 2023-20 (2023-15 I.R.B. 636), requesting that methyl methacrylate-ethyl methacrylate-methacrylic acid copolymer in a styrene solution ((C5
H8
O2)x
-(C6
H10
O2)y
-(C4
H6
O2)z
-(C8
H8)s; x=75.76, y=8.46, z=1, s=168.4) be added to the list of taxable substances under section 4672(a) of the Internal Revenue Code (List). The petition requesting the addition of methyl methacrylate-ethyl methacrylate-methacrylic acid copolymer in a styrene solution ((C5
H8
O2)x
-(C6
H10
O2)y
-(C4
H6
O2)z
-(C8
H8)s; x=75.76, y=8.46, z=1, s=168.4) to the List is based on weight and contains the information detailed in paragraph (b) of this document. The information is provided for public notice and comment pursuant to section 9 of Rev. Proc. 2022-26. The publication of petition information in this notice of filing is not a determination and does not constitute Treasury Department or IRS confirmation of the accuracy of the information published.
(b)
Petition Content.
(1)
Substance name:
Methyl methacrylate-ethyl methacrylate-methacrylic acid copolymer in a styrene solution ((C5
H8
O2)x
-(C6
H10
O2)y
-(C4
H6
O2)z
-(C8
H8)s; x=75.76, y=8.46, z=1, s=168.4).
(2)
Petitioner:
AOC Resins and Coatings, Inc. and AOC, LLC, are importers of methyl methacrylate-ethyl methacrylate-methacrylic acid copolymer in a styrene solution ((C5
H8
O2)x
-(C6
H10
O2)y
-(C4
H6
O2)z
-(C8
H8)s; x=75.76, y=8.46, z=1, s=168.4).
(3)
Proposed classification numbers:
(i)
HTSUS number:
3906.90.5000.
(ii)
Schedule B number:
3906.90.6000.
(iii)
CAS number:
55765-89-4; 100-42-5.
(4)
Petition filing dates:
(i)
Petition filing date for purposes of making a determination:
August 12, 2025.
(ii)
Petition filing date for purposes of section 11.02 of Rev. Proc. 2022-26, as modified by section 3 of Rev. Proc. 2023-20:
January 1, 2023.
(5)
Description from petition:
Methyl methacrylate-ethyl methacrylate-methacrylic acid copolymer in a styrene solution ((C5
H8
O2)x
-(C6
H10
O2)y
-(C4
H6
O2)z
-(C8
H8)s; x=75.76, y=8.46, z=1, s=168.4) is a thermoplastic low-profile additive that expands and thus counteracts the shrinking of the polyester resin as it gels and cures ensuring a smooth surface of the molded part.
Methyl methacrylate-ethyl methacrylate-methacrylic acid copolymer in a styrene solution ((C5
H8
O2)x
-(C6
H10
O2)y
-(C4
H6
O2)z
-(C8
H8)s; x=75.76, y=8.46, z=1, s=168.4) is made from benzene, propylene, methane, ammonia, sulfuric acid, and ethylene. Taxable chemicals constitute 81.05 percent by weight of the materials used to produce this substance.
(6)
Process identified in petition as predominant method of production of substance:
The predominant method of producing methyl methacrylate-ethyl methacrylate-methacrylic acid copolymer in a styrene solution ((C5
H8
O2)x
-(C6
H10
O2)y
-(C4
H6
O2)z
-(C8
H8)s; x=75.76, y=8.46, z=1, s=168.4) is by dissolving 33 percent 7016 IAXP Acrylic Copolymer in 67 percent styrene. 7016 IAXP Acrylic Copolymer is produced via free-radical polymerization of methyl methacrylate, ethyl methacrylate, and methacrylic acid monomers.
Methyl methacrylate monomer is produced from acetone, hydrogen cyanide, sulfuric acid, and methanol. Acetone is produced from benzene and propylene. Hydrogen cyanide is produced from methane and ammonia. Methanol is produced from syngas and hydrogen is produced from steam-reforming methane.
Ethyl methacrylate monomer is produced from acetone, hydrogen cyanide, sulfuric acid, and ethanol. Ethanol is produced via bio-fermentation.
Methacrylic acid monomer is produced from acetone, hydrogen cyanide, and sulfuric acid.
Styrene is produced by the dehydrogenation of ethylbenzene using superheated steam over an iron(III) oxide catalyst. Ethylbenzene is produced via a Friedel-Crafts reaction of benzene and ethylene.
(7)
Stoichiometric material consumption equation, based on process identified as predominant method of production:
(x+y+z+s) C6
H6
(benzene) + (x+y+z) C3
H6
(propylene) + (5/2x+y+z) CH4
(methane) + (x+y+z) NH3
(ammonia) + 5/2(z+y+x) O2
(oxygen) + (x+y+z) H2
SO4
(sulfuric acid) + x CO (syngas) + y CH3
CH2
OH (ethanol) + s C2
H4
(ethylene) → (C5
H8
O2)x
-(C6
H10
O2)y
-(C4
H6
O2)z
-(C8
H8)s
(methyl methacrylate-ethyl methacrylate-methacrylic acid copolymer in a styrene solution) + (x+y+z) C6
H5
OH (phenol) + (2x+3y+2z) H2
O (water) + 1/2x CO2
(carbon dioxide) + (x+y+z) NH4
HSO4
(ammonium hydrogen sulfate) + s H2
(hydrogen)
(8)
Tax rate calculated by Petitioner, based on Petitioner's conversion factors for taxable chemicals used in production of substance:
(i)
Tax rate:
$11.55 per ton.
(ii)
Conversion factors:
0.76 for benzene, 0.14 for propylene, 0.08 for methane, 0.06 for ammonia, 0.32 for sulfuric acid, and 0.18 for ethylene.
(9)
Public docket number:
IRS-2025-0599.
Michael H. Beker,
Senior Counsel (Energy, Credits, and Excise Tax), IRS Office of Chief Counsel.