OT:RR:NC:N5:116
Ms. Erica Fritz
Director, US Trade Services
GHY USA, Inc.
572 South 5th Street
Pembina, ND 58271
RE: The country of origin determination for the purpose of eligibility under the USMCA and for the
application of additional trade remedies of aluminum drip edge roof flashing
Dear Ms. Fritz:
In your letter dated December 10, 2025, you requested a country of origin determination for the purpose of
eligibility under the United States-Mexico-Canada Agreement (“USMCA”) on behalf of your client, City
Sheet Metal (“CSM”).
The products to be imported are aluminum drip edge roof flashing. The flashing is described as a shaped
aluminum sheet installed at the edge of a roof for the purpose of directing water away from fascia and into
the gutter. The product is manufactured from black aluminum coil that is smelt and cast in either China or the
United States (“U.S.”) and you have requested a determination for both scenarios. Regardless of the country
of smelt and cast of the black aluminum coil, the manufacturing process remains the same. Black aluminum
coil from either China or the U.S. is imported into Canada. At the time of arrival in Canada, the coil is
pre-painted, 42.5 inches wide, and either 0.012 inch or 0.017 inch thick. In Canada, the coil is unwound, slit
to a width of 5.25 inches and cut into individual ten feet long strips. The aluminum strips are bent into the
shape of the roof flashing and then packaged and shipped to the U.S. At the time of import into the U.S., the
product is ready to be installed with some cutting and trimming required at the jobsite.
Although you have not requested a classification determination, you suggest the flashing is classified under
subheading 7610.10, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
aluminum structures (excluding prefabricated buildings of heading 9406) and parts of structures (for
example, bridges and bridge-sections, towers, lattice masts, roofs, roofing frameworks, doors and windows
and their frames and thresholds for doors, balustrades, pillars and columns); aluminum plates, rods, profiles,
tubes and the like, prepared for use in structures: doors, windows and their frames and thresholds for doors.
We disagree. The appropriate subheading for the roof flashing will be 7604.29.1090, HTSUS, which provides
for aluminum bars, rods and profiles: of aluminum alloys: other: other profiles: other. The duty will be 5
percent, ad valorem.
USMCA
Regarding the request for a country of origin determination for purposes of eligibility under USMCA, the
USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018.
The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA
Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note (“GN”) 11 of the
HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an
originating good for purposes of the USMCA. GN 11(b) states:
For the purposes of this note, a good imported into the customs territory of the United States from the
territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff
treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule
as a “good originating in the territory of a USMCA country” only if—
the good is a good wholly obtained or produced entirely in the territory of one or more USMCA
countries;
the good is a good produced entirely in the territory of one or more USMCA countries, exclusively
from originating materials;
the good is a good produced entirely in the territory of one or more USMCA countries using
non-originating materials, if the good satisfies all applicable requirements set forth in this note
(including the provisions of subdivision (o));
In the scenario in which the aluminum coil is smelt and cast in the U.S., the good is wholly obtained or
produced entirely in the territory of one or more USMCA countries. Therefore, in this scenario, we find that
the aluminum drip edge flashing will be originating and will qualify for eligibility under the USMCA.
In the scenario in which the aluminum coil is smelt and cast in China, the good is not considered wholly
obtained or produced entirely in a USMCA country under GN 11(b)(i), nor is the good produced exclusively
from originating materials per GN 11(b)(ii). Therefore we must determine whether the product qualifies
under GN 11(b)(iii). The flashing is classified under heading 7604, HTSUS, at the time of importation into
the U.S. The applicable rule of origin for goods classified under heading 7604, HTSUS, is in GN 11(o),
HTSUS, which provides in relevant part:
Heading rule:
4. A change to heading 7604 from any other heading.
At the time of importation into Canada, the coil would be classified under heading 7606, HTSUS, which
provides for aluminum plates, sheets and strip, of a thickness exceeding 0.2 mm. Because a change in
heading from 7606 to 7604 will occur in Canada, we find that where Chinese black aluminum coil is used the
flashing will also be eligible for preferential tariff treatment under the USMCA.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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, 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