CLA-2-73:OT:RR:NC:N5:117
Ivan Kaic
Hjulsbro Steel
Tallbergvagen 43
Linkoping, 58939
Sweden
RE: The country of origin of nonalloy prestressed concrete (PC) Strand
Dear Mr. Kaic:
In your letter dated July 13, 2025, you requested a country of origin ruling.
The product to be imported is nonalloy prestressed concrete (PC) Strand. The PC Strand consists of 7-wire
construction and is made to EN ISO 16120-1:2017 or EN ISO 16120-4:2017 standards. This product will be
imported in coils and wrapped in paper to protect the coils from corrosion during transport.
The applicable subheading for the PC Strand will be 7312.10.3012, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for Stranded wire ropes, cables, plaited bands, slings and the like, of
iron or steel, not electrically insulated: Stranded wire, rope and cables: Stranded wire: Other: Other: For
prestressing concrete: other. The rate of duty will be free.
In your request, you state that wire rod with a diameter of 11 and 13 mm is manufactured in the United
Kingdom (U.K.) from steel that is melted and poured in the U.K. Next, the wire rod is shipped in coils to
Sweden and first undergoes pickling to remove away the scale. Then the wire is continuously cold-drawn
where the wire is reduced in 8 to 9 steps to 4.1 to 5.3 mm in diameter. Afterwards, seven wire spools are
placed in a stranding machine where the wires are stranded into PC Strand. Lastly, the PC Strand is coiled
and wrapped in paper for transport to the United States.
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a
substantial transformation will occur is whether an article emerges from a process with a new name,
character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v.
United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See
National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
Based on the facts presented, drawing of wire from wire rod does not substantially transform the wire rod that
originated in the U.K. The court in Superior Wire v. United States, 669 F. Supp. 472 (CIT 1987), aff'd, 867
F.2d 1409 (Fed. Cir. 1989), held that the drawing of wire rod into wire did not constitute a substantial
transformation, as there was no significant change in the use or character of the wire, and only a relatively
insignificant change in name. Further, we find that the additional twisting of the wire into PC Strand is not
complex enough to constitute a substantial transformation. Therefore, the country of origin of the PC Strand
is the United Kingdom.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties of 25% for derivative iron or steel products of the United Kingdom are
reflected in Chapter 99, headings 9903.81.96, 9903.81.97, and 9903.81.98. Products provided by heading
9903.81.98, as well as products of Chapter 73 provided by 9903.81.96 and 9903.81.97, will be subject to a
duty of 25% percent upon the value of the steel content. At the time of entry, you must report the Chapter 99
heading applicable to your product classification, i.e. 9903.81.97, in addition to subheading 7312.10.3012,
HTSUS. Derivative iron or steel products processed in another country from steel articles melted and poured
in the United States, provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
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 the United Kingdom, will be subject to an additional 10 percent ad valorem rate of duty. Your
product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading
applicable to your product classification, i.e. 9903.01.33, in addition to subheading 7312.10.3012, 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 and Border Protection
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].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division