The country of origin of aluminum plate

N354482
October 27, 2025
OT:RR:NC:N5:116
CATEGORY: Country of Origin Ms. Vanessa Bertl Lodec USA 27 Elmwood Lane Fair Haven, New Jersey 07704 RE: The country of origin of aluminum plate Dear Ms. Bertl: In your letter dated October 1, 2025, you requested a country of origin ruling for the purposes of marking and for the purposes of applicability of trade remedies. The products to be imported are described as cut plates with a thickness of 50 mm or less that have not been coated, plated, or machined. The plates are produced to either Aluminum Alloy Series Designation (AASD) number 6082 or 6061. According to your submission, the manufacturing begins in South Africa, where bauxite is processed to produce primary aluminum. The liquid primary aluminum is cast into slabs before being exported to China. In China, the slabs are hot-rolled and cold-rolled to produce aluminum plate with a thickness of 50 mm or less. The plate is not machined, drilled, punched or coated in China. No further processing is required after its importation into the United States (U.S.). 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). You indicate that unwrought slabs are shipped from South Africa to China. In China, the unwrought, semi-finished slabs are hot-rolled and cold-rolled to produce a finished plate with a thickness of 50 mm or less. There are numerous precedent rulings that have determined that slabs are substantially transformed when manufacturing steps take semi-finished products (aluminum slabs) into finished products (aluminum plate) by hot-rolling. See rulings HQ 950924, dated 3/30/1992, HQ 562122, dated 11/26/2001, HQ 081659, dated 3/3/1989 and N350709, dated 7/8/2025. The product in question is both hot-rolled and cold-rolled in China, resulting in a substantial transformation. The country of origin for the purposes of marking and for the purposes of applicability of trade remedies of the finished aluminum alloy plate is China.

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 [email protected].
Sincerely,
(for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division