CLA-2-25:OT:RR:NC:N2:237
Mr. Robert Soral
Oil-Dri Corporation of America
410 N. Michigan Avenue
Chicago, Illinois 60611
RE: Tariff classification of Calibrin-Z 100% natural calcium montmorillonite CAS-1302-78-9. Dear Mr. Soral: In your letter dated July 21, 2011 you requested a tariff classification ruling. You submitted a Mineral Analysis Report of Calibrin-Z Products and a Quality Control Report of Calibrin-Z Mine, prepared by William F. Moll & Associates dated July 1, 2009, along with a flow chart and MSDS.
Calibrin-Z consists of 100% natural bentonite (calcium montmorillonite type) extracted from a mine, crushed, dried, sized, pulverized and packaged. No chemical activation is performed. No chemicals are added at any time during processing. The final product is a natural clay powder. Mineral Analysis on 3 lots of the finished product by X-Ray Diffraction (XRD) and X-Ray Fluorescence (XRF) shows a composition of: silicon dioxide (69.1-70.6%), aluminum trioxide (14.5-15.1%), ferric oxide (6.8-7.11%), magnesium oxide (2.36-2.45%), potassium oxide (1.41-1.45%), calcium oxide (0.65-0.70%) and sodium oxide (<0.05-0.06%). Typical pH is 3.5-5.5. The calcium content exceeds the sodium and confirms that the montmorillonite is of the calcium type.
Quality Analysis by XRD on 59 raw samples taken from different vertical and horizontal locations in the mine shows that calcium montmorillonite is naturally occurring. The mine is in a geological formation known to contain calcium montmorillonite. Raw and processed samples are very similar chemically with no significant difference. Calibrin-Z is 100% natural calcium montmorillonite.
The applicable subheading for Calibrin-Z 100% natural calcium montmorillonite clay powder is 2508.10.00, Harmonized Tariff Schedule of the United States, which provides for: Bentonite.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
If you have any questions regarding the ruling, contact National Import Specialist Frank Cantone at (646) 733-3038.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division