The tariff classification and county of origin of structural steel framing from Armenia

N363014 July 16, 2026 CLA-2-73:OT:RR:NC:N5:463 CATEGORY: Classification; Origin TARIFF NO.: 7308.90.9590 Khachik Khachatryan X Steel Frame 7901 4th St N 13458 St. Petersburg, FL 33702 RE: The tariff classification and county of origin of structural steel framing from Armenia Dear Mr. Khachatryan: In your letter dated July 9, 2026, you requested a tariff classification and country of origin determination ruling. The product under consideration is structural steel framing designed to form the skeleton of a building. The structural steel framing components, are manufactured to EN 10305-5 standard, including, but not limited to wall framing panels, roof framing assemblies, floor framing systems, and structural beams. These components are fabricated in Armenia using Chinese-origin galvanized steel coils. All components are shipped together in an unassembled condition, ready for assembly into a finished structure upon arrival in the United States. In your letter, you suggest that the structure is classifiable in subheading 9406.20, HTSUS. We disagree. The structure is not a prefabricated building as imported into the United States. A prefabricated building must be either a complete building, or it must have the essential character of a prefabricated building. The structure is a mere framework with no walls, roof, or floor, and, as such, it does not have the essential character of a prefabricated building. The Explanatory Notes to the Harmonized System indicate that “Presented separately, parts of buildings and equipment, whether or not identifiable as intended for these buildings, are excluded from the heading and are in all cases classified in their own appropriate headings.” The structure is merely a part of a building and, therefore, is excluded from heading 9406. Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance with the General Rules of Interpretation (GRI’s). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1 and if the headings and legal notes do not otherwise require, the remaining GRIs may then be applied. As stated in your submission, the structural steel framing components are shipped unassembled. GRI 2(a) states as follows: Any reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as entered, the incomplete or unfinished article has the essential character of the complete or finished article. It shall also include a reference to that article complete or finished (or failing to be classified as complete or finished by virtue of this rule), entered unassembled or disassembled. Furthermore, the Harmonized Commodity Description and Coding System Explanatory Notes (“ENs”) constitute the official interpretation of the Harmonized System at the international level. While not legally binding, the ENs provide a commentary on the scope of each heading of the HS and are thus useful in ascertaining the proper classification of merchandise. See T.D. 89-90, 54 Fed. Reg. 35127 (August 23, 1989). The ENs to GRI 2(a) provide, in relevant part, that: (V) The second part of Rule 2(a) provides that complete or finished articles presented unassembled or disassembled are to be classified in the same heading as the assembled article. When goods are so presented, it is usually for reasons such as requirements or convenience of packing, handling or transport. (VI) This Rule also applies to incomplete or unfinished articles presented unassembled or disassembled provided that they are to be treated as complete or finished articles by virtue of the first part of this Rule. The applicable subheading for the structural steel framing, as described above, will be 7308.90.9590, HTSUS, which provides for Structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge sections, lock gates, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, shutters, balustrades, pillars and columns) of iron or steel; plates, rods, angles, shapes, sections, tubes and the like, prepared for use in structures, of iron or steel: Other: Other: Other: Other: Other. The rate of duty will be free. When determining the country of origin for purposes of applying current trade remedies under Section 232 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). Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/current. 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 stated above, 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 the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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, please contact National Import Specialist ChingJu (Claudia) Lin at chingju.lin@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division