Mr. Paul S. Anderson
Sonnenberg & Anderson
125 South Wacker Drive
Suite 1825
Chicago, IL 60606

RE: The tariff classification of bronze powder from Germany

Dear Mr. Anderson:

In your letter dated December 1, 2011 you requested a tariff classification ruling on behalf of your client ECKART America Corporation. Technical data sheets and a sample of the powder were also submitted.

The powder, which is graded Rotoflex Pale XA8-203 59935/G, is designed for use in the graphic arts and printing ink industries as a metallic pigment in the manufacture of inks. It is not used primarily as a metallic pigment in the manufacture of paint but it can also be used for that purpose. As imported it is stated to be not dispersed in either aqueous or non-aqueous media or in paste form or any other semi-liquid dispersion.

The manufacturing process is described as follows: atomization of refined copper and refined zinc which has been molten into an alloy; atomized powder is then ground four separate times through a ball mill to process the powder from spherical shape to lamellar structure; the lamellar shaped flakes are then polished and stearic acid is added to prevent agglomeration; and, finally the flakes are blended to produce a uniform batch of powder which is packaged in 55 gallon drums or 12 gallon pails.

The subject powder sample was submitted to the Customs Laboratory which determined that it is a copper zinc alloy powder of lamellar structure.

Based on the information submitted and the laboratory report the applicable subheading for the subject powder will be 7406.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for copper powders and flakes: powders of lamellar structure; flakes. 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 Mary Ellen Laker at (646) 733-3020.


Thomas J. Russo
National Commodity Specialist Division