The country of origin of magnesium powder, granules, and raspings

N356481 December 17, 2025 OT:RR:NC:N5:116 CATEGORY: Country of Origin Lucas Theo Rehaag German American Chamber of Commerce, Inc. 120 Wall Street, 20th Floor New York, New York 10005 RE: The country of origin of magnesium powder, granules, and raspings Dear Mr. Rehaag: In your letter dated November 26, 2025, you requested a country of origin determination for marking purposes on behalf of your client, Magnezyum ve Metal Tozlar Endüstri ve Ticaret A (“MME”). The products to be imported are magnesium powder, granules, and raspings/chips. According to your submission, magnesium ingots (over 99.90 % purity) from Turkey, Israel, or China are made into magnesium powder, granules, and raspings/chips by MME at their processing facility in Turkey and undergo the following manufacturing steps: The magnesium ingots are ground into coarse chips by using special cutting machines and are then further reduced in size by using a size reduction mill according to customer specifications. If the end products are raspings, smaller raspings will be screened in the final step of the production process. To produce granules or powder, the raspings undergo processing in a granulator. The final step of the production process is screening to obtain the exact grain size of the powder, granules, or raspings. After quality control inspection, the powder, granules, or raspings are packaged and then shipped to the United States. When determining the country of origin for purposes of marking, 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). Based on the manufacturing process, it is the opinion of this office, that a substantial transformation has taken place in Turkey. Magnesium ingots are converted into three different magnesium products: powder, granules, and raspings/chips. These products are separate and distinct articles of commerce, as they possess a new name, character and different uses. You state that magnesium powder is primarily used in the pyrotechnics, welding, and refractory industries, magnesium granules are mainly used in hot metal desulphurization in the iron and steel industry, and magnesium raspings/chips are primarily used for metalorganic compounds and for the manufacture of perfumes, pharmaceuticals, etc. As such, we find that the country of origin of the magnesium powder, granules, and raspings/chips for marking purposes will be Turkey. 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