CLA-2-73:OT:RR:NC:N5:121
9903.01.33; 9903.88.03
Haojun Sun
Tech Forge SDN. BHD.
No. 7, Pesiaran Industri Rapat 2, Kawasan Perindustrian Sri Rapat
31350 Ipoh, Perak, Malaysia 31350
Malaysia
RE: The country of origin of steel threaded rod
Dear Mr. Sun:
In your letter dated August 20, 2025, you requested a tariff classification and country of origin determination
ruling.
The articles under consideration are described as ALL THREAD ROD (Part number ROD). These are fully
threaded rods made of certified low-alloy Corten weathering steel. The threaded rod is made to (but not
limited to) the following diameters and lengths: 5/8" x 12", 3/4" x 12" to 36", 1" x 24" to 40", and 1-1/4" x
36" to 48". The finished rods meet AWWA C111 standards for ductile iron pipe connections in water
infrastructure applications.
You describe a manufacturing process in which the wire rod from Vietnam or China is shipped to Malaysia.
In Malaysia the coiled wire is straightened and cut to specific required lengths, the cut ends are beveled to
remove sharp edges, the country of origin and any necessary grade markings are permanently cold-forged
onto the product, threads are cut or rolled along the entire length of the rod, and then the final products are
inspected and prepared for shipment.
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).
In determining whether a substantial transformation has occurred in the processing of metals, CBP has
generally held that the mere cutting to length and threading do not constitute a substantial transformation.
Accordingly, we find that the processing of the wire rod in Malaysia as described above, which includes
cutting, threading, beveling, and inspecting, does not constitute a substantial transformation. Thus, from the
details submitted, we find that the country of origin for the ALL THREAD ROD (Part number ROD) will be
determined by the wire rod (in this case either Vietnam or China).
The applicable subheading for the ALL THREAD ROD (Part number ROD) will be 7318.15.5051,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for Screws, bolts, nuts, coach
screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of
iron or steel: Threaded articles: Other screws and bolts, whether or not with their nuts or washers: Studs:
Other: Continuously threaded rod: Of alloy steel. The duty rate will be free.
If the country of origin of the steel wire rod is Vietnam, the following additional tariffs apply:
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter
99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as
products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 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. 9903.81.90, in addition to subheading 7318.15.5051, 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 of Vietnam will be
subject to an additional ad valorem rate of duty of 20 percent. 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 7318.15.5051, HTSUS, listed above.
If the country of origin of the steel wire rod is China, the following additional tariffs apply:
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 7318.15.5051, HTSUS, listed above.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter
99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as
products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 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. 9903.81.90, in addition to subheading 7318.15.5051, 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 of China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 7318.15.5051, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 7318.15.5051, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report Chapter 99 subheading 9903.88.03 in
addition to subheading 7318.15.5051, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
The merchandise in question may be subject to antidumping duties and countervailing duties (AD/CVD) for
alloy and certain carbon steel threaded rod from China (A-570-104, C-570-105). Written decisions regarding
the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade
Administration of the Department of Commerce (ITA) and are separate from tariff classification and origin
rulings issued by Customs and Border Protection (CBP). General information regarding the ITA and
AD/CVD can be found at https://www.trade.gov/us-antidumping-and-countervailing-duties. The ITA’s
“Guide on How to File for an Antidumping/Countervailing Duty Scope Ruling Request” is available at
https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf
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/.
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, please contact
National Import Specialist Jennifer Jameson at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division