OT:RR:NC:N5:116
Ms. Vanessa Bertl
Lodec USA
27 Elmwood Lane
Fair Haven, New Jersey 07704
RE: The country of origin of aluminum plate
Dear Ms. Bertl:
In your letter dated October 1, 2025, you requested a country of origin ruling for the purposes of marking and
for the purposes of applicability of trade remedies.
The products to be imported are described as cut plates with a thickness of 50 mm or less that have not been
coated, plated, or machined. The plates are produced to either Aluminum Alloy Series Designation (AASD)
number 6082 or 6061. According to your submission, the manufacturing begins in South Africa, where
bauxite is processed to produce primary aluminum. The liquid primary aluminum is cast into slabs before
being exported to China. In China, the slabs are hot-rolled and cold-rolled to produce aluminum plate with a
thickness of 50 mm or less. The plate is not machined, drilled, punched or coated in China. No further
processing is required after its importation into the United States (U.S.).
When determining the country of origin for purposes of marking and for the purposes of applying current
trade remedies and additional duties, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter 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).
You indicate that unwrought slabs are shipped from South Africa to China. In China, the unwrought,
semi-finished slabs are hot-rolled and cold-rolled to produce a finished plate with a thickness of 50 mm or
less. There are numerous precedent rulings that have determined that slabs are substantially transformed
when manufacturing steps take semi-finished products (aluminum slabs) into finished products (aluminum
plate) by hot-rolling. See rulings HQ 950924, dated 3/30/1992, HQ 562122, dated 11/26/2001, HQ 081659,
dated 3/3/1989 and N350709, dated 7/8/2025. The product in question is both hot-rolled and cold-rolled in
China, resulting in a substantial transformation. The country of origin for the purposes of marking and for the
purposes of applicability of trade remedies of the finished aluminum alloy plate is China.
The merchandise in question may be subject to antidumping duties and countervailing duties (AD/CVD).
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 and are separate from tariff
classification and origin rulings issued by Customs and Border Protection (CBP). You can contact them at
https://trade.gov/enforcement/ (click on “Contact Us”). For your information, you can view a list of current
AD/CVD cases at the Department of Commerce ITA website at
https://www.trade.gov/data-visualization/adcvd-proceedings, and you can search AD/CVD deposit and
liquidation messages using CBP’s AD/CVD Search tool at https://aceservices.cbp.dhs.gov/adcvdweb.
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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division