OT:RR:NC:N1:128
Michael Forster
Teijin Carbon America, Inc.
121 Cardiff Valley Rd
Rockwood, TN 37854
RE: The country of origin of carbon fiber products.
Dear Mr. Forster:
In your letter dated July 23, 2026, you requested a country of origin ruling.
The merchandise under consideration is chopped carbon fibers, item numbers 103 Tenax-A HT C124 3mm,
105 Tenax-A HT C124 12mm, 106 Tenax-A HT C124 25mm, 109 Tenax-A HT C451 3mm, and 110
Tenax-A HT C451 6mm; pelletized carbon fibers, item numbers 250 Tenax-A IM P303 3mm, 260 Tenax-A
HT P722 3mm, 265 Tenax-A HT P802 3mm, and 270* Tenax-A HT P303 3mm; and milled carbon fibers,
item numbers 344 Tenax-A HT M100 100mu and 345 Tenax-A HT M100 60mu. The chopped and pelletized
fibers are used as an additive in plastic compounds for electronic, automotive, and medical applications,
while the milled fibers are used in ESD (electrostatic discharge) floor coatings and in plastic compounds
which require increased electrical connectivity.
From the information you provided, carbon fiber filament yarn is imported into the United States from Japan
or Germany and then processed into chopped carbon fibers, pelletized carbon fibers, or milled carbon fibers.
To manufacture the chopped carbon fibers, the filament yarn is immersed in a sizing oil bath if not already
coated in sizing oil, then dried. You state that the sizing oil makes the yarn more cohesive and reduces fuzz.
Fibers destined for the 104 and 105 series products are fed into a direct chopper; fibers for the other products
are collected and dry-chopped to various sizes depending on the final product.
To manufacture the pelletized carbon fibers, the carbon fiber filament yarn is fed into a wet chopper. The
chopped filaments are moved into a pin mixer and blended with sizing oil. This blended material is then fed
into a zig zag blender, which shapes the filaments into pellets. After drying, the pellets are screened, boxed
up, and shipped to customers.
To manufacture the milled carbon fibers, the carbon fiber filament yarn is dried over steam dryers, collected,
and fed into a hammer mill, where the fibers are milled. The milled fibers are fed into a baghouse, collected,
then boxed up and shipped to customers.
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).
The carbon fiber filament yarn imported from Japan or Germany is identifiable as carbon fiber upon
importation into the United States. It remains identifiable as carbon fiber after it is chopped, milled, or
pelletized. The processes which take place in the United States do not affect the chemical and physical
properties of the carbon fiber, and do not change the material in name, character, or use. As such, the
domestic processing does not effect a substantial transformation.
The country of origin of the chopped carbon fibers, item numbers 103 Tenax-A HT C124 3mm, 105 Tenax-A
HT C124 12mm, 106 Tenax-A HT C124 25mm, 109 Tenax-A HT C451 3mm, and 110 Tenax-A HT C451
6mm; pelletized carbon fibers, item numbers 250 Tenax-A IM P303 3mm, 260 Tenax-A HT P722 3mm, 265
Tenax-A HT P802 3mm, and 270* Tenax-A HT P303 3mm; and milled carbon fibers, item numbers 344
Tenax-A HT M100 100mu and 345 Tenax-A HT M100 60mu will be Japan or Germany as applicable.
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 Nicole Sullivan at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division