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Issues: Whether Zirconium Washed Dried Frit (ZDF), obtained by processing Zircon Sand with sodium hydroxide and water leaching, was classifiable as Zirconium ore concentrate under Heading 26.15 or as zirconium oxide/hydroxide under Heading 28.25.
Analysis: The starting material was Zircon Sand containing zirconium silicate and silica. The processing converted the zirconium silicate into crude zirconium hydroxide, resulting in a change in chemical composition and structure. Under the HSN notes to Chapter 26, processes for ore preparation may not alter the chemical composition of the basic compound, except in cases such as calcination, roasting or firing. The fusion process used here was not within that exception. Chapter 28 covers separate chemically defined compounds, even if they contain impurities, and zirconium hydroxide/hydrous zirconium oxide is specifically covered by Heading 28.25. The HSN notes also exclude from Chapter 26 concentrates obtained by treatments that alter chemical composition or crystallographic structure and place them in Chapter 28.
Conclusion: ZDF was correctly classifiable under Heading 28.25 and not under Heading 26.15.
Ratio Decidendi: Where processing alters the chemical composition and structure of the basic ore and produces a separate chemically defined compound, the resulting product falls outside Chapter 26 and is classifiable under the specific heading in Chapter 28.
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