The country of origin of stainless steel pipes and tubes

N357814 February 9, 2026 OT:RR:NC:N5:116 CATEGORY: Origin Patrick Caulfield Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP 599 Lexington Avenue, Floor 36 New York, New York 10022 RE: The country of origin of stainless steel pipes and tubes Dear Mr. Caulfield: In your letter dated January 14, 2026, you requested a country of origin ruling for the purposes of marking and for the purposes of the applicability of trade remedies on behalf of your client, Atlantic Steel Industries PTE. LTD. The products to be imported are Types 304/304L or 316/316L stainless steel pipes and tubes meeting ASTM A312, the Standard Specification for Seamless, Welded, and Heavily Cold Worked Austenitic Stainless Steel Pipes. You indicate that these round welded pipes and tubes are manufactured from hot-rolled and cold-rolled stainless steel coil/strip and have an outside diameter ranging from 12.7 mm to 219.1 mm and a wall thickness ranging from 1.0 mm to 8.2 mm. The pipes and tubes are used in various industries (i.e., Chemical and Petrochemical Industry, Pulp & Paper Industry) and applications (i.e., heat exchangers, condensers, water treatment systems, and structural and architectural installations). When determining the country of origin for purposes of marking and for the 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). According to your submission, hot-rolled and/or cold-rolled stainless steel coil/strip from various countries including Indonesia, India, and Brazil is sent to the Dominican Republic where it undergoes the following operations to produce pipes and tubes: (1) tube forming, (2) welding, (3) annealing/solution heat treatment, (4) pickling, (5) polishing, (6) testing, and (7) packaging then subsequently imported into the United States. Based on the manufacturing processes performed in the Dominican Republic, this office finds that a substantial transformation has taken place. Stainless steel coil/strip is shipped to the Dominican Republic where it is manufactured into pipes and tubes, new products with a different commercial use. Accordingly, the country of origin for the purposes of marking and for the purposes of applicability of trade remedies of the stainless steel pipes and tubes is the Dominican Republic. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division