Lisa Chen
Millennia Stainless Inc.
10016 Romandel Avenue
Santa Fe Springs, CA 90670

RE:      The country of origin of stainless steel sheet

Dear Ms. Chen:

In your letter dated July 7, 2023, you requested a country of origin ruling.

The product to be imported is polished and coated Grade 304 or 430 stainless steel sheet. This cold-rolled, cut-to-length sheet ranges in thickness from 0.018” (0.45 mm) to 0.135” (3.42 mm) and has a width up to 60” (1524 mm). The nickel content ranges from .75% to 10.5%. The sheets are made to ASTM A240/A240M and will be used in the production of end use products such as appliances or outdoor grills.

Flat-rolled products are defined in Chapter 72, Note 1(k) as “Rolled products of solid rectangular (other than square) cross section…in the form of…straight lengths, which if of a thickness less than 4.75 mm are of a width measuring at least 10 times the thickness or if of a thickness of 4.75 mm or more are of a width which exceeds 150 mm and measures at least twice the thickness.”

The applicable subheading for the polished and coated stainless steel sheet will be 7219.90.0025, Harmonized Tariff Schedule of the United States (HTSUS), which provides for flat-rolled products of stainless steel, of a width of 600 mm or more, other, other, containing more than 0.5 percent by weight of nickel, other. The rate of duty will be free.

In your country of origin request you describe a scenario wherein stainless steel is melted and poured in Indonesia. It is then hot-rolled, pickled, and annealed. Lastly, the steel is cold-rolled to a 2B mill finish and then shipped to China in coil form for further processing. In China, the coil is polished, slit into sheets and a polyvinyl chloride (PVC) coating is applied to one side and an anti-fingerprint coating is applied to the opposite side. Finally, the sheets are cut-to-length and then packaged for export.

Part 134, Customs Regulations (19 CFR Part 134), implements the country of origin marking requirements of 19 U.S.C. §1304. Pursuant to 19 CFR 134.1(b), “country of origin” means the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of this part. As stated in HQ 735009, dated July 30, 1993, “The country of origin is the country where the article last underwent a “substantial transformation,” that is, processing which results in a change in the article's name, character, or use.”

Based on the facts presented, it is the opinion of this office that the imported stainless steel sheet did not undergo a substantial transformation in China. The manufacturing operations performed in China such as polishing, slitting, PVC and anti-fingerprint coating, and cutting to length did not change the name, character or use of the sheet. Accordingly, the country of origin of the stainless steel sheet originating from stainless steel coil produced in Indonesia and imported into the U.S. from China will be Indonesia.  

On March 8, 2018, Presidential proclamations 9704 and 9705 imposed additional tariffs and quotas on a number of steel and aluminum mill products.  Exemptions have been made on a temporary basis for some countries. Quantitative limitations or quotas may apply for certain exempted countries and can also be found in Chapter 99. Additional duties for steel of 25 percent and for aluminum of 10 percent are reflected in Chapter 99, subheading 9903.80.01 for steel and subheading 9903.85.03 for aluminum. Products classified under subheading 7219.90.0025, HTSUS, may be subject to additional duties or quota.  At the time of importation, you must report the Chapter 99 subheading applicable to your product classification in addition to the Chapter 72, 73 or 76 subheading listed above.

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 Denise Hopkins at [email protected].


Steven A. Mack
National Commodity Specialist Division