Mr. Joseph Mulvey
OIJ International, LLC
11 Isaac Street
Second Floor
Norwalk, Connecticut 06850-4107

RE: The tariff classification of a magnesium oxide composite board from China

Dear Mr. Mulvey:

In your letter, dated January 20, 2011, you requested a tariff classification ruling regarding a product described as “Magnesium Oxide Composite Board.”

A sample measuring twelve inches by twelve inches was submitted with your ruling request. The information submitted with your ruling request indicates that the complete product will measure four feet by eight feet. You stated that the board will be one-half inch thick.

The submitted sample was sent to our Customs and Border Protection Laboratory for analysis. Our laboratory has now completed its analysis.

According to the information submitted with your ruling request, the board will be used as a replacement for plywood.

You stated that the board consists of magnesium oxide, magnesium chloride, glass fibers, perlite, wood powder, calcium carbonate and other components.

Our laboratory has determined that the article consists principally of magnesium oxychloride cement, which is formed by reacting magnesium chloride, magnesium oxide and water. Among other components, this cement board contains glass fibers, which serve as strengthening agents or reinforcement for the cement. Thus, the board consists of cement reinforced with glass fibers. The applicable subheading for the magnesium oxide composite board will be 6811.82.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for articles of asbestos-cement, of cellulose fiber-cement or the like: not containing asbestos: other sheets, panels, tiles and similar articles. The rate of duty will be free.

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 Jacob Bunin at 646-733-3027.


Robert B. Swierupski
National Commodity
Specialist Division