OT:RR:NC:N5:117
Lucas Theo Rehaag
German American Chamber of Commerce, Inc.
120 Wall Street, 20th Floor
New York City, NY 10005
RE: The country of origin of calcium silicide cored wire
Dear Mr. Rehaag:
In your letter dated November 3, 2025, you requested a country of origin ruling on on behalf of your client,
Metser Demir Celik.
The products under consideration are five calcium silicide (CaSi) cored wire variants consisting of a steel
tubular sheath that encapsulates the calcium silicide powder that will be added to the steel melt. Based on the
chemistry provided, the CaSi cored wire variants meet the definition of a ferroalloy in accordance with
Chapter 72, Note 1(c), Harmonized Tariff Schedule of the United States (HTSUS).
The applicable subheading for the CaSi cored wire variants will be 7202.99.8040, HTSUS, which provides
for Ferroalloys: Other: Other: Other: Other. The general rate of duty will be 5 percent ad valorem.
According to your submission, CaSi powder which originates in China, Brazil, or Argentina is shipped to
Turkey where it is joined together with steel strip of Turkish origin and made into cored wire. In Turkey, the
steel strip is uncoiled and roll-formed into a U-shaped profile. The CaSi powder is then fed into the U-shaped
channel which is then crimped to form a sealed steel tube (capsule) around the powder, which is then drawn
into wire, coiled, wrapped, labelled, palletized, and subsequently shipped to customers.
When determining the country of origin for purposes of applying current trade remedies under Section 232
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).
Based on the facts presented, it is the opinion of this office that encapsulating the calcium silicide powder in
a steel sheath does not result in a substantial transformation. This office finds that country of origin of the
CaSi powder determines the origin of the foreign article. (See Ruling NY M84229) As such, the country of
origin of the five CaSi cored wire variants will be the country in which the powder originates (i.e., China,
Brazil, or Argentina).
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 10 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, 7202.99.8040, HTSUS.
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. 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 7202.99.8040, HTSUS.
Effective August 6, 2025, Executive Order 14323 imposed additional duties on products from Brazil. At this
time, products of Brazil provided by heading 9903.01.77, except for products described in headings
9903.01.78 – 9903.01.83, will be subject to an additional ad valorem rate of duty of 40 percent. At the time
of entry, you must report the Chapter 99 heading applicable to your product classification, i.e., 9903.01.77, in
addition to subheading 7202.99.8040, HTSUS.
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 Brazil will be
subject to an additional ad valorem rate of duty of 10 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e., 9903.02.09, in addition to subheading
7202.99.8040, HTSUS.
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 Argentina will
be subject to an additional ad valorem rate of duty of 10 percent. 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
7202.99.8040, HTSUS.
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, please contact
National Import Specialist Denise Hopkins at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division