CLA-2-38:OT:RR:NC:N3:135
Debby Anderson
Odyssey International Services
305 Bridgepoint Drive
South St Paul, MN 55075
RE: The country of origin of ICR 1001
Dear Ms. Anderson:
In your letter dated May 21, 2026, on behalf of your client, Chevron Lummus Global, you requested a tariff
classification and country of origin determination ruling. Additional information was provided via email
dated June 1 and June 11, 2026. The classification of the product will be addressed in a separate
correspondence.
ICR 1001 is described as a hydroprocessing catalyst in the form of shaped solid extrudates. It contains
NiMoW-001(CAS 1351378-24-9), Cellosize, and ethylene glycol. Under hydrogen at elevated temperature
and pressure in refinery operation, ICR 1001 facilitates critical hydroprocessing reactions, such as
hydrodesulfurization and hydrodenitrogenation. These reactions are essential for removing sulfur and
nitrogen compounds and upgrading hydrocarbon feedstocks for clean fuel production in a refinery.
The manufacturing process begins with the combination of Chinese-origin NiMoW-001 powder,
Germany-origin Cellosize or Methocel (CAS number 9004-65-3) from an undisclosed country, South
Korea-origin ethylene glycol, and water. This blend is mixed to create a wet paste, which is then pressed
through an extruder equipped with die buttons featuring proprietary asymmetric quadrilateral-shaped holes.
As the mixture passes through, it forms long, wet noodles that are subsequently dried at 300 °F in a vibrating
belt dryer.
Once dried, the noodles are routed through sizing equipment and cut into precise dimensions required for the
finished catalyst. The final extrudates have an asymmetric quadrilateral shape, with diameters ranging from
1.5 to 3.0 mm and lengths between 3 to 8 mm. Among their notable physical properties is a crush strength
exceeding 5 lb/mm, underscoring their durability and reliability during refinery operations.
The entire manufacturing process takes place in South Korea. After production, ICR 1001 is ready for
shipment and immediate use in refinery operations.
You explain that NiMoW-001 functions as the catalytically active metal precursor phase incorporated into
ICR 1001 hydroprocessing catalysts for petroleum refining applications. Cellosize or Methocel is organic
extrusion aid used to improve rheology and plasticity during extrusion. Its use increases extrusion rate,
improves the crush strength, adjusts particle density and porosity of the finished ICR 1001. Ethylene glycol
functions as an extrusion aid as well to control behaviors and moisture retention, which helps improve crush
strength and control particle density. The 300 °F vibrating belt dryer operation is a drying step intended
primarily to remove free and physically adsorbed water from the wet extrudates.
You claim that the ICR 1001 manufacturing process converts the raw materials, such as NiMoW-001 and
Cellosize powders, into a formed catalyst body suitable for refinery hydroprocessing reactor loading and
industrial refining use. The process changes the physical form, pore structure, and mechanical properties
while preserving the intended catalytic function of the NiMoW-001 component.
Physical changes includes (a) transformation from 10 micron dry powder to extrudate particles in asymmetric
quadrilateral shape with diameters ranging from 1.5 to 3.0 mm and lengths between 3 to 8 mm, (2) extrudate
particle having crush strength greater than 5 lb/mm, (3) unique pore structure, with well distributed macro-
(>50 nm) and meso-pores (2-50 nm), generated during peptization in the mixer, extrusion and drying. Crush
strength results from NiMoW-001 particle interactions with Cellosize and ethylene glycol, as well as from
extrusion and drying. Size is controlled by adjusting moisture levels during extrusion and by using cutters
and screening after drying.
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).
In determining whether a substantial transformation occurs in the manufacture of products from chemicals,
Customs has consistently examined whether a chemical reaction occurs when two chemicals are mixed in the
production of the final article. In this instance, Cellosize and ethylene glycol are added to NiMoW-001 as
extrusion aids to form a wet paste with water. The paste is then extruded, dried, sized, and cut to produce the
final product, ICR 1001. The drying process primarily removes water, while Cellosize and ethylene glycol
remain in ICR 1001. Thus, ICR 1001 contains NiMoW-001, Cellosize, and ethylene glycol. Although the
process alters the physical form, pore structure, and mechanical properties of the NiMoW-001 powder, no
chemical reaction occurs during manufacturing. The Chinese-origin NiMoW-001 powder does not undergo
substantial transformation as a result of the operations that occur in South Korea, and its intended catalytic
function and use remain unchanged. Therefore, the country of origin for ICR 1001 is China.
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 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, please contact
National Import Specialist Fei Chen at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division