Tariff classification turns on actual product character; washed clay remained unactivated, so Chapter 2505 applied.

Tariff classification depended on the product's technical character: expert opinions and test reports showed Bleach-9 was only washed clay, not activated clay or earth, because washing and drying did not amount to activation and the product retained its raw clay character. On that uncontroverted evidence, the product was correctly classified under Chapter Heading 2505 as a mineral substance and not under Chapter Heading 3802 as an activated natural mineral product, so the departmental appeal failed.

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Issues: Whether the product sold as Bleach-9 was correctly classifiable under Chapter Heading 2505 as a mineral substance or under Chapter Heading 3802 as an activated natural mineral product.

Analysis: The classification dispute turned on the technical character of the product. The adjudicating authority relied on expert opinions and test reports indicating that the product was only washed clay and not activated clay or earth. Those reports stated that washing clay with water and drying it does not amount to activation and that the product retained the character of raw clay. No contrary evidence was produced by the department to dislodge those technical findings.

Conclusion: The product was rightly classified under Chapter Heading 2505 and not under Chapter Heading 3802, and the departmental appeal failed.

Ratio Decidendi: In a tariff classification dispute, where uncontroverted technical evidence shows that the product retains its natural character and is not an activated product, classification must follow the product's actual composition and properties.

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