N352654

N352654 September 16, 2025 CLA-2-73:OT:RR:NC:N5:121 CATEGORY: Classification; Country of Origin TARIFF NO.: 7318.15.5051; 9903.81.90; 9903.01.33 OR 7318.15.5051; 9903.01.24; 9903.81.90; 9903.01.33; 9903.88.03 Haojun Sun Tech Forge SDN. BHD. No. 7, Pesiaran Industri Rapat 2, Kawasan Perindustrian Sri Rapat 31350 Ipoh, Perak, Malaysia 31350 Malaysia RE: The country of origin of steel threaded rod Dear Mr. Sun: In your letter dated August 20, 2025, you requested a tariff classification and country of origin determination ruling. The articles under consideration are described as ALL THREAD ROD (Part number ROD). These are fully threaded rods made of certified low-alloy Corten weathering steel. The threaded rod is made to (but not limited to) the following diameters and lengths: 5/8" x 12", 3/4" x 12" to 36", 1" x 24" to 40", and 1-1/4" x 36" to 48". The finished rods meet AWWA C111 standards for ductile iron pipe connections in water infrastructure applications. You describe a manufacturing process in which the wire rod from Vietnam or China is shipped to Malaysia. In Malaysia the coiled wire is straightened and cut to specific required lengths, the cut ends are beveled to remove sharp edges, the country of origin and any necessary grade markings are permanently cold-forged onto the product, threads are cut or rolled along the entire length of the rod, and then the final products are inspected and prepared for shipment. 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 has occurred in the processing of metals, CBP has generally held that the mere cutting to length and threading do not constitute a substantial transformation. Accordingly, we find that the processing of the wire rod in Malaysia as described above, which includes cutting, threading, beveling, and inspecting, does not constitute a substantial transformation. Thus, from the details submitted, we find that the country of origin for the ALL THREAD ROD (Part number ROD) will be determined by the wire rod (in this case either Vietnam or China). The applicable subheading for the ALL THREAD ROD (Part number ROD) will be 7318.15.5051, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: Threaded articles: Other screws and bolts, whether or not with their nuts or washers: Studs: Other: Continuously threaded rod: Of alloy steel. The duty rate will be free. If the country of origin of the steel wire rod is Vietnam, the following additional tariffs apply: On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter 99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 percent upon the value of the steel content. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.81.90, in addition to subheading 7318.15.5051, HTSUS. Derivative iron or steel products processed in another country from steel articles melted and poured in the United States, provided for in heading 9903.81.92, are not subject to the additional ad valorem duties. 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 Vietnam will be subject to an additional ad valorem rate of duty of 20 percent. Your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.33, in addition to subheading 7318.15.5051, HTSUS, listed above. If the country of origin of the steel wire rod is China, the following additional tariffs apply: 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 20 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 7318.15.5051, HTSUS, listed above. On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter 99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 percent upon the value of the steel content. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.81.90, in addition to subheading 7318.15.5051, HTSUS. Derivative iron or steel products processed in another country from steel articles melted and poured in the United States, provided for in heading 9903.81.92, are not subject to the additional ad valorem duties. 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. Your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.33, in addition to subheading 7318.15.5051, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 7318.15.5051, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report Chapter 99 subheading 9903.88.03 in addition to subheading 7318.15.5051, HTSUS, listed above. The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively. The merchandise in question may be subject to antidumping duties and countervailing duties (AD/CVD) for alloy and certain carbon steel threaded rod from China (A-570-104, C-570-105). Written decisions regarding the scope of AD/CVD orders 

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 has occurred in the processing of metals, CBP has generally held that the mere cutting to length and threading do not constitute a substantial transformation. Accordingly, we find that the processing of the wire rod in Malaysia as described above, which includes cutting, threading, beveling, and inspecting, does not constitute a substantial transformation. Thus, from the details submitted, we find that the country of origin for the ALL THREAD ROD (Part number ROD) will be determined by the wire rod (in this case either Vietnam or China). The applicable subheading for the ALL THREAD ROD (Part number ROD) will be 7318.15.5051, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: Threaded articles: Other screws and bolts, whether or not with their nuts or washers: Studs: Other: Continuously threaded rod: Of alloy steel. The duty rate will be free. If the country of origin of the steel wire rod is Vietnam, the following additional tariffs apply: On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter 99, headings 9903.81.89, 9903.81.90, an