CLA-2-73:OT:RR:NC:N5:117
Daniel Seabra
FAPRICELA - Indústria de Trefilaria, S.A.
Manga da Granja
Cantanhede, 3060-071
Portugal
RE: The country of origin of nonalloy steel prestressed concrete (PC) Strand
Dear Mr. Seabra:
In your letter dated February 24, 2026, you requested a country of origin ruling.
The product to be imported is nonalloy steel prestressed concrete (PC) Strand made to EN ISO 16120-1:2017
and EN ISO 16120-4:2017 standards. The PC Strand consists of a 7-wire construction (six outer wires
helically wound around a central core wire). You indicate that the six outer wires and the central core wire
are both made of nonalloy steel and that the strand may or may not be coated with corrosion preventative
compounds depending on customer specifications. This product is imported in coils and wrapped in paper to
protect the coils from corrosion during transport. The PC Strand will be used in prestressed concrete
applications including bridges, buildings, and other civil engineering structures.
The applicable subheading for the nonalloy steel 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.
According to your submission, wire rod with a diameter of 11 or 13 mm is manufactured in the United
Kingdom from steel that is melted and poured in the United Kingdom. Next, the wire rod is shipped to
Portugal where it undergoes mechanical descaling to remove surface oxides and is cold-drawn into wire
through a series of dies to achieve the specified diameter and mechanical properties. Afterwards, seven wire
spools are placed in a stranding machine where six wires are helically wound around one central core wire to
form the 7-wire strand. The strand may or may not be coated to prevent corrosion depending on customer
specifications. Lastly, the PC Strand is coiled and packaged 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 United Kingdom. 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 PC Strand is the United Kingdom.
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)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division