CLA-2-76:OT:RR:NC:N5:116

Mr. Larry M. Friedman
Barnes, Richardson & Colburn LLP
303 E Wacker
Chicago, Illinois 60601

RE: The tariff classification of aluminum crop ends from Korea

Dear Mr. Friedman:

In your letter dated June 2, 2025, you requested a tariff classification ruling on behalf of your client, HMA, Inc.

The products under consideration are identified as aluminum “crop ends,” which are the end sections that are cut off from a billet. According to your submission, primary aluminum that is sourced from India, Australia, and Russia is sent to Korea where it is melted, cast into a billet, homogenized, and the ends are cut. The billets are made from type 6061 and 6063 aluminum alloy. Once the ends are cut off, they are imported into the United States and sold to customers who will melt the crop ends and make them into new billets.

You indicate that the aluminum “crop ends” subject to this request are of an inconsistent chemistry, are not uniform in size, have physical defects (i.e., cracks, bubbles, etc.) resulting from the casting process, and are leftover scrap from the manufacturing of the billets. Based on the information provided, this office finds that the “crop ends” meet the Section XV, Note 8(a) definition of waste and scrap. Due to the manufacturing operations, the “crop ends” have no other use than to be remelted before being made into new billets after importation.

The applicable subheading for the aluminum crop ends will be 7602.00.0097, HTSUS, which provides for aluminum waste and scrap: other recyclable aluminum. The rate of duty will be free.

Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries, including Korea, will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e., 9903.01.25, in addition to subheading 7602.00.0097, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/current.

The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.

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 Angelia Amerson at [email protected].
Sincerely,

(for)
Steven A. Mack
Director
National Commodity Specialist Division