The country of origin of seamless stainless steel pipes

N354423 October 24, 2025 OT:RR:NC:N5:116 CATEGORY: Country of Origin Mr. Richard Mojica Miller & Chevalier Chartered 900 16th St. NW Washington, District of Columbia 20006 RE: The country of origin of seamless stainless steel pipes Dear Mr. Mojica: In your letter dated September 30, 2025, you requested a country of origin ruling for the purposes of applicability of trade remedies on behalf of your client, Toyota Tsusho America, Inc. (“TAI”). The products to be imported are finished, seamless, stainless steel pipes typically used in refineries and chemical plants. According to your submission, the manufacturing begins in China, where either billets or solid stainless steel bars are hot-pierced to produce hollow tubes (green tubes). The green tubes are then pickled and cold-drawn before being shipped to Japan. In Japan, the green tubes are degreased, annealed, straightened, cut, chamfered or beveled, pickled, inspected, and tested before being shipped to the United States (U.S.). The annealing process includes heating the green tubes to 1040 degrees Celsius and quickly quenching them, which increases the steel’s grain size and changes the steel from martensitic steel to austenitic steel. In addition to the increase in grain size, the annealing process changes the steel’s mechanical properties, specifically its yield strength, tensile strength, and hardness. When determining the country of origin for purposes of applying current trade remedies and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter 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). You indicate that green tubes from China are sent to Japan for further processing (i.e., degreasing, annealing, straightening, cutting, chamfering/beveling, etc.). Based on the information provided, this office finds that the operations performed in Japan do result in a substantial transformation since a new and different article does emerge. The pipes enter Japan as green tubes, unsuitable for their intended use in refineries and chemical plants and leave Japan as ASTM certified pipes suitable for their intended use. As such, we find that the country of origin for the purposes of trade remedy applicability is Japan. The merchandise in question may be subject to antidumping duties and countervailing duties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). You can contact them at https://trade.gov/enforcement/ (click on “Contact Us”). For your information, you can view a list of current AD/CVD cases at the Department of Commerce ITA website at https://www.trade.gov/data-visualization/adcvd-proceedings, and you can search AD/CVD deposit and liquidation messages using CBP’s AD/CVD Search tool at https://aceservices.cbp.dhs.gov/adcvdweb. 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 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 Angelia Amerson at angelia.m.amerson@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division