The country of origin of steel tubing processed in Korea or Japan from green tubes originating in India, China or Russia.

N118180 September 3, 2010 CLA-2-73:OT:RR:NC:1:117 CATEGORY: Country of origin Kathleen M. McGuire Customs Compliance Specialist/ Corporate Regulatory Compliance Toyota Tsusho America, Inc. 1300 Post Oak Blvd. Suite 1850 Houston, TX 77056 RE: The country of origin of steel tubing processed in Korea or Japan from green tubes originating in India, China or Russia. Dear Ms. McGuire: In your letter dated August 5, 2010 you requested a country of origin determination ruling. The item you intend to import is steel threaded and coupled OCTG casing and tubing. You are requesting a ruling on country of origin for this product when it is imported from Korea or Japan. The original material is green tube or unfinished seamless steel pipe made in India, China or Russia. The manufacturing process begins with billets which are pierced to make a hollow tube and then rolled to a specified size. The green tubes are intended to be exported to Korea or Japan where they will be heat treated, ends threaded and couplings attached. You have stated your position that as a result of the processing in Korea or Japan that a new and different product known as OCTG, (Oil Country Tubular Goods) has been produced. You believe that a substantial transformation has occurred changing the country of origin from India, China, or Russia to Korea or Japan. Although threading and coupling alone would not result in a substantial transformation, heat treating has been held to substantially transform green tubes into oil well tubing. Heat treating imparts the critical high yield strength required by A.P.I. specifications for oil well tubing. This office is of the opinion that a substantial transformation has taken place sufficient to change the country of origin to Korea or Japan. 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 Mary Ellen Laker at (646) 733-3020. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division