William Jordan Brouillette
Showa Denko Materials (America), Inc.
2150 North First Street
San Jose, CA 95131

RE: The tariff classification of surface modified graphite from Japan

Dear Mr. Brouillette:

In your letter dated March 31, 2022, you requested a tariff classification ruling on a modified graphite.

The material goes by a product code SMG-N. SMG-N is manufactured by taking natural graphite powder that is in a spherical form, mixing it with a carbonaceous material, heating the graphite until there is an amorphous carbon layer to it, and then subjecting it to crushing, and sieving operations, and then packaging it for export. After importation SMG-N will be used in making anode preparations for copper electrodes that will be used in the manufacture of lithium-ion batteries.

The applicable subheading for the modified graphite will be 3801.10.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Artificial graphite; colloidal or semi-colloidal graphite; preparations based on graphite or other carbon in the form of pastes, blocks, plates or other semimanufactures: Artificial graphite: Other. The rate of duty will be free.

This merchandise may be subject to the requirements of the Toxic Substances Control Act (TSCA), which are administered by the U. S. Environmental Protection Agency. Information on the TSCA can be obtained by contacting the EPA at 1200 Pennsylvania Avenue, N.W., Washington, D.C. 20460, by calling the TSCA Assistance Line at (202) 554-1404, by e-mail to: [email protected] or by visiting their website at

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on the World Wide Web at

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist John Bobel at [email protected].


Steven A. Mack
National Commodity Specialist Division