Classification of Micronised Zircon sand / Zirconium Silicate (Opacifier)

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.... marketed as Zircon opacifier is classifiably under chapter Heading 26.15 as zirconium ores and concentrates, 2839.90 as silicates, 3207.90 as prepared opacifier or 2505.00 as mineral substances (NES). 2. The matter has been examined. The manufacturing process of the product reportedly is that the zirconium silicate sand is wet grinded in the ball mills with flint pebbles and transferred to vib....

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.... to make it fit for use as Opacifier. This micronisation would not have been necessary for extraction of zirconium metal for which ore/ore concentrate could be used. Thus, fine grinding/micronisation of zircon cant not be considered a process normal to metallurgical industry. No chemical transformation of original material (zirconium silicate sand) is involved during micronisation, and there is on....

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.... was viewed that these basically were intended to change physical dimensions which micronised the zirconium sand and there is otherwise no chemical change. Such micronised sand could be used as Opacifier in enamel manufacture but these were not "prepared Opacifier" of Chapter Heading 32.07. Even in HSN such micronised sands were treated essentially as mineral substance NES and classified under Hea....