Sydney Mintzer
Mayer & Brown, LLP
1999 K Street, NW
Washington DC 20006

RE: The tariff classification of ammonium niobium oxalate ("ANO") from Brazil

Dear Mr. Mintzer:

In your letter dated March 11, 2019, you requested a tariff classification ruling on behalf of your client, CBMM North America, Inc.

The product is identified as ammonium niobium oxalate ("ANO"), an organometallic chemical that is used in the production of heterogeneous catalysts, electronic ceramics, optical lenses, thin films, special coatings and energy-related devices (e.g., lithium ion batteries, fuel cells, and super-capacitors). ANO is in the form of an odorless white, fine crystalline powder. It is stable in ambient atmosphere and water soluble. ANO is packaged and shipped in 50 kilogram drums. ANO is a multi-constituent substance that consists of two main organic components:

1. Ammonium oxalate oxalic acid 2[NH4(C2HO4) . (C2H2O4) . 2(H2O) 22% w/w 2. Ammonium oxobisozalato niobate NH4(NbO(C2O4)2(H2O)2) . 3(H2O) 78% w/w

In addition to the two main components listed above, ANO also contains minor impurities that account for less than one percent of its composition. Such impurities include sodium, potassium, chlorine, and sulfate.

The applicable subheading for ammonium niobium oxalate ("ANO") will be 3824.99.9297, HTSUS, which provides for: 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: Other: Other: Other. The rate of duty will be 5%.

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 Patrick Day at


Steven A. Mack
National Commodity Specialist Division