CLA-2-73:OT:RR:NC:N5:117
Carlo Formaggio CB Trafilati Acciai SPA Via Laghi 64 Tezze sul Brenta, 36056 Italy RE: The country of origin of nonalloy steel prestressed concrete (PC) Strand Dear Mr. Formaggio: In your letter dated September 26, 2025, you requested a country of origin ruling. The product to be imported is galvanized nonalloy steel prestressed concrete (PC) Strand. The PC Strand consists of a 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. You suggest classification of the galvanized PC strand in subheading 7312.10.3074, 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, ropes, and cables: Stranded wire: Other: Other: Other: Other: Galvanized: Other: Other. We disagree. This office finds that the galvanized PC strand is more specifically provided for elsewhere in subheading 7312.10, HTSUS. The applicable subheading for the galvanized PC Strand will be 7312.10.3012, HTSUS, which provides for Stranded wire, ropes, cables, plaited bands, slings and the like, of iron or steel, not electrically insulated: Stranded wire, ropes 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 ranging from 11 to 15 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 Italy and first undergoes pickling to remove away the scale. The wire is continuously cold-drawn where the wire is reduced in 8 to 9 steps to a diameter between 4.22 and 6.05 mm. A thin protective layer of zinc is
then applied to the surface of the steel to prevent corrosion by means of a hot-dipped galvanizing process. Afterwards, seven wire spools are placed in a stranding machine where the wires are twisted 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 galvanized 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. f 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division