Mr. Sudheer Chikkere
Ecoiria LLC
2104 Adams Avenue
San Leandro, CA 94577

RE: The tariff classification of expanded clay pebbles and expanded clay and coco coir pebbles from the Netherlands.

Dear Mr. Chikkere:

In your letter received February 5, 2019, you requested a tariff classification ruling.

The merchandise under consideration is referred to as Pure Hydroton and HydroCoco Mix. Samples were submitted with your ruling request and were forwarded to the Customs and Border Protection Laboratory for analysis. This analysis has been completed.

The Pure Hydroton and HydroCoco Mix are irregularly spherical in shape and are of various sizes. The Pure Hydroton pebbles measure approximately .75 inches across at their widest points, while the HydroCoco Mix pebbles measure between approximately .5 inches and .75 inches at their widest points. You state that the Pure Hydroton is comprised of expanded clay, while the HydroCoco is comprised of 60 percent expanded clay and 40 percent coco coir by weight. From the information you provided, these pebbles are designed as growing mediums for hydroponic and aquaponic techniques.

Laboratory analysis has determined that the Pure Hydroton is comprised of expanded clay, while the HydroCoco Mix is comprised of expanded clay and plant material.

The HydroCoco Mix is a composite good comprised of different materials that are classifiable in different headings. Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRIs) taken in order. GRI 3(b) of the HTSUS provides, in relevant part, that composite goods which cannot be classified by reference to GRI 3(a) shall be classified as if they consisted of the material or component which gives them their essential character. The expanded clay component provides the essential character of this item.

The applicable subheading for the Pure Hydroton pebbles and the HydroCoco Mix pebbles will be 6806.20.0000, HTSUS, which provides for “Slag wool, rock wool and similar mineral wools; exfoliated vermiculite, expanded clays, foamed slag and similar expanded mineral materials…: Exfoliated vermiculite, expanded clays, foamed slag and similar expanded mineral materials (including intermixtures thereof).” The general 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 the 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 Nicole Sullivan at [email protected].


Steven A. Mack
National Commodity Specialist Division