Newly Released CBP HQ Rulings for Oct. 9
The Customs Rulings Online Search System (CROSS) was updated on Oct. 9 with the following headquarters ruling (ruling revocations and modifications will be detailed elsewhere in a separate article as they are announced in the Customs Bulletin):
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H313009: Protest and Application for Further Review No. 5301-20-104797; chlorine removal promoted zeolites
| Ruling: 3824.99.3900, “Prepared binders for foundry molds or cores; chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included: Other: Other: Other: Mixtures of two or more inorganic compounds: Other.” |
| Issue: Whether the instant merchandise is classified in heading 3815 as reaction initiators, reaction accelerators or catalytic preparation, or in heading 3824 as other chemical products and preparations. |
| Item: UNICAT Catalyst Technologies' CLX-13X and CLX-16E, which are two chlorine removal promoted zeolite catalysts. The CLX-13X is for the removal of organic chlorides only, while the CLX-16E is a high capacity, promoted Zeolite for the removal of inorganic and organic chlorides in either gas or liquid applications such as natural gas, naphtha, refinery off-gas or light to medium range, liquid hydrocarbons. |
| Reason: The CLX-13X and CLX-16E are described (and commercially known) as “molecular sieves,” referring to the pore trapping function of the instant products. A molecular sieve is a material, typically a metal oxide, that forms three-dimensional lattice patterns. These structures create cavities of precise dimensions that then function as molecular filters, allowing molecules of a certain size to pass through and blocking those of a larger size. Thus, there is no catalytic reaction occurring in the “pore size trapping” function of the instant products. Similarly, the adsorption of chloride molecules to the surface of the zeolite is not a catalytic chemical reaction, as it does not require a chemical initiator to lower the activation energy of the reaction. As neither the CLX-13X nor CLX-16E has a catalytic function, both products are precluded from heading 3815. Thus, because neither of the CLX-13X and CLX-16E chemical preparation products is described by any other heading in the HTSUS, they are classified as entered, in heading 3824, as a chemical preparation not elsewhere specified or included. |
| Ruling Date: Aug. 5, 2024 |