RE: The country of origin of Low Carbon Ferrochrome (LCR)

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365380 October 13, 2026 CLA-2-72:OT:RR:NC:N5:117 CATEGORY: Origin TARIFF NO.: 7202.49.5090 Sefary Rodriguez Yusen Logistics (Americas) Inc. 230-79 International Airport Center Blvd., Suite 200 Springfield Gardens, NY 11413 United States RE: The country of origin of Low Carbon Ferrochrome (LCR) Dear Ms. Rodriguez: In your letter dated September 24, 2026, you requested a country of origin ruling on behalf of your client, Hanwa American Corp. The product to be imported is Low Carbon Ferrochrome (LCR) in lump form measuring 10 – 50 mm. According to the chemistry submitted, the LCR meets the definition of a ferroalloy in accordance with Chapter 72, Note 1(c). The applicable subheading for the Low Carbon Ferrochrome (LCR) will be 7202.49.5090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Ferroalloys: Ferrochromium: Other: Other: Other. The general rate of duty will be 3.1 percent ad valorem. According to your submission, the subject ferrochrome is manufactured in Vietnam from raw materials originating in China, which are silico-chrome alloy, chromite ore, and quicklime. In Vietnam, the raw materials are blended in an automated portioning system. After blending, they are fed into an electric-arc furnace where they undergo smelting, reduction, and refining. Next, the molten metal is poured into molds, cooled, mechanically crushed, and packaged for export to the United States. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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). It is the opinion of this office that a substantial transformation has taken place in Vietnam. The raw materials are combined and converted through a series of steps resulting in Low Carbon Ferrochrome. Ferrochrome is a separate and distinct article of commerce which possesses a new name, character and use from the starting materials. As such, the country of origin is the Vietnam. 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. f 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 and Border Protection 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 Denise Hopkins at denise.hopkins@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division