Mr. M. Andrew Gray
W.R. Grace &Co.
7500 Grace Drive
Columbia MD 21044

RE: The tariff classification of catalytic preparations from China

Dear Mr. Gray:

In your letter dated January 21, 2008 you requested a tariff classification ruling.

In your letter you requested that confidential treatment be given to certain information in your submission. In a telephone conversation and subsequent email with National Import Specialist Richard Dunkel you withdrew that request. We are hereby issuing our ruling in full.

The compounds RV-27 LL and RV-27 HL, which you state are to be used as catalytic preparations, are to be incorporated into fluid cracking catalysts. These catalysts are used by petroleum refiners to break down high molecular weight hydrocarbon feedstock. In your request, you indicated that the two products RV-27 LL and RV-27 HL consist of a combination of lanthanum hydroxycarbonate and aluminum hydroxychloride in varying concentrations. These compounds undergo a chemical reaction to produce the imported product which you indicated in your initial request to have an uknown stoichiometry. In subsequent phone conversations and document submissions it was explained that the initial slurry reacts to form a “solid solution” which may contain varying amounts of un-reacted input materials. The amounts of the unreacted materials will vary based on the quality of the raw materials and other factors involved in processing of the slurry.

The applicable subheading for the RV-27 LL and the RV-27 HL will be 3815.90.3000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: Reaction initiators, reaction accelerators and catalytic preparations, not elsewhere specified or included: Other: Consisting wholly of inorganic substances: Other: The rate of duty will be Free.

This merchandise may be subject to the requirements of the Toxic Substances Control Act (TSCA), which are administered by the United States Environmental Protection Agency. Information on the TSCA can be obtained by contacting the EPA at 1200 Pennsylvania Avenue, N.W., Mail Code 70480, Washington, D.C., by telephone at (202) 554-1404, or by visiting their website at

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Paul Hodgkiss at 646-733-3046.


Robert B. Swierupski
National Commodity
Specialist Division