Sodium Chloride/Pure Vacuum Dried (PVD) Iodized Salt Not Subject to Excise Tax

May 24, 1999 BIR RULING NO. 072-99 107 (A)-157-000-00-072-99 Sytengco Enterprises Corporation No. 10 Resthaven St., San Francisco Del Monte Quezon City Attention: Mr . Necisto Sytengco President Gentlemen : This refers to your letter dated March 15, 1999 requesting, in effect, for confirmation of your opinion that Sodium Chloride/Pure Vacuum Dried (PVD) Iodized Salt is not a mineral product under Sec. 151(B) (3) of the Tax Code of 1997, hence, not subject to the excise tax imposed therein. It is represented that unlike the natural or rock salt deposit found in Pangasinan, the imported Aquatic Pure Vacuum Salt is produced from sea water; that the preparation of the raw brine into Pure Vacuum Dried Salt undertakes several steps, i.e., purification, evaporation at 120c to get salt slurry, centrifugation to produce pure salt with moisture content not exceeding 2.5%, drying at 140c to achieve pure dehydrated salt with 99.9% sodium chloride content by weight and maximum moisture content at 0.1%, after which the dehydrated salt is transferred to the packing machine. llcd You have also presented samples of the Pure Vacuum Dried Iodized Salt pursuant to Republic Act No. 8172, otherwise known as "An Act Promoting Salt Iodization Nationwide and For Related Purposes." Based on the foregoing, the imported salt in question does not fall under the definition of mineral products which is defined to mean things produced and prepared in a marketable state by simple treatment processes such as washing or drying, but without undergoing any chemical change or process or manufacturing. (Sec. 151(B)(3), Tax Code of 1997) Such being the case, your importation of Sodium Chloride/Pure Vacuum Dried (PVD) Iodized Salt is subject only to the 10% value-added tax prescribed under Sec. 107(A) of the Tax Code of 1997 but not to the excise tax imposed under Sec. 151 of the same Code. This serves as our authority to secure the release of the aforesaid importation from customs custody without the payment of excise tax. Very truly yours, (SGD.) BEETHOVEN L. RUALO Commissioner Internal Revenue