OT:RR:CTF:VS H346896 ACH

Mariana Vincent
Reliant Customs Broker
7920 Airway Rd
San Diego, CA 92154

RE: Subheading 9801.00.10, HTSUS; Cardboard Scrap

Dear Ms. Vincent:

This is in response to your letter, dated April 2, 2025, on behalf of your client, Reliable Container LLC (“Reliable Container”), concerning the applicability of subheading 9801.00.10, Harmonized Tariff Schedule of the United States (“HTSUS”) to cardboard scrap. Your request was forwarded to this office from the National Commodity Specialist Division for review. Our ruling is set forth below.

FACTS:

The item under consideration is scrap of U.S.-origin corrugated cardboard. Reliable Container, located in Cerritos, California, exports U.S. origin precut corrugated carton sheets to its plant in Tijuana, Mexico. The finished products manufactured in Mexico are corrugated cardboard boxes in different shapes and sizes. In Mexico, during the manufacturing process, the excess corrugated material is “punched out,” similar to a cookie cutter, to shape the box. The cutting generates less than 10 percent waste. The corrugated cardboard waste is then compacted into bales and returned to the U.S. for recycling. Reliable Container indicates that the resulting scrap has no added value, and its condition remains unchanged.

ISSUE:

Whether the cardboard scrap is eligible for duty-free treatment under subheading 9801.00.10, HTSUS.

LAW AND ANALYSIS:

Subheading 9801.00.10, HTSUS, provides for the duty-free treatment of: Products of the United States when returned after having been exported, or any other products when returned within 3 years after having been exported, without having been advanced in value or improved in condition by any process of manufacture or other means while abroad.

While some change in the condition of the product while it is abroad is permissible, operations which either advance the value or improve the condition of the exported product render it ineligible for duty-free entry upon return to the U.S. Border Brokerage Co. v. United States, 65 Cust. Ct. 50, C.D. 4052, 314 F. Supp. 788 (1970), appeal dismissed, 58 CCPA 165 (1970).

In Burgess Battery Co. v. United States, C.D. 866 (1944), appeal dismissed, 32 CCPA 207 (1944), zinc sheets of U.S. origin were sent to Canada to be used in the manufacture of battery cups. Zinc trimmings from the irregular top edges of the cups were returned to the U.S. as scrap. The court pointed out that while the exported articles (zinc strips) had been changed in condition from the time of their exportation to the time of their importation, the processing abroad affecting the imported materials were processes of segregation and elimination and not manufacturing operations and did not serve to increase their value or improve their condition. Therefore, the returned scrap qualified for duty-free treatment as American goods returned under a predecessor statute.

Additionally, in Headquarters Ruling Letter (“HQ”) W557348, dated August 31, 1993, CBP determined that scrap from U.S. origin fabric cut into garment pieces in Mexico was eligible for duty-free treatment under subheading 9801.00.10, HTSUS. Since CBP and the Customs Court have ruled previously that creating scrap material neither increases in value nor improves the condition of the exported cardboard, the merchandise will be eligible for duty-free treatment under subheading 9801.00.10, HTSUS.

19 C.F.R. § 10.1 sets forth the documentary requirements for entry under subheading 9801.00.10, HTSUS. We note that CBP has not yet amended the regulations to implement the change to subheading 9801.00.10, HTSUS. Nonetheless, 19 C.F.R. § 10.1(a)(1) provides that the foreign shipper declare the following information with regard to articles in a shipment valued over $2,500: the port of exportation, the date of exportation, the quantity, the description of the merchandise, the value of the merchandise, the date of the declaration, and whether the articles were returned without having been advanced in value or improved in condition by any process of manufacture or other means. In addition, the documentation is to be filed “in connection with the entry.”

19 C.F.R. § 10.1(a)(2) requires the owner, importer, consignee, or agent having knowledge of the facts regarding the claim for free entry to declare that the foreign shipper’s statement is true, that the articles were not manufactured or produced in the United States under subheading 9813.00.05, HTSUS, and that the articles were exported from the United States without benefit of drawback. The information required also pertains to the name of the manufacturer, the location of the manufacturer, and the date of the declaration. The three-year time limit is not applicable here because the cardboard scrap is considered a product of the

2 United States. Provided the documentary requirements are satisfied, the cardboard scrap will be eligible for duty-free treatment under subheading 9801.00.10, HTSUS.

HOLDING:

Based on the information presented, the cardboard scrap at issue is eligible for duty-free treatment under subheading 9801.00.10, HTSUS, provided the documentary requirements of 19 C.F.R. § 10.1 are satisfied.

Please note that 19 C.F.R. § 177.9(b)(1) provides that “[e]ach ruling letter is issued on the assumption that all of the information furnished in connection with the ruling request and incorporated in the ruling letter, either directly, by reference, or by implication, is accurate and complete in every material respect. The application of a ruling letter by a Customs Service field office to the transaction to which it is purported to relate is subject to the verification of the facts incorporated in the ruling letter, a comparison of the transaction described therein to the actual transaction, and the satisfaction of any conditions on which the ruling was based.”

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is entered. If the documents have been filed without a copy, this ruling should be brought to the attention of the CBP officer handling the transaction.

Sincerely,

Monika R. Brenner, Chief
Valuation and Special Programs Branch

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