CBP Ruling N360018 — The country of origin of lithographed tinplate steel sheet

Tariff classification

HTS codes: 1801, 2026, 1201, 1992, 1993, 1982, 1000, 1130, 2018

Headings: 1801, 2026, 1201, 1992, 1993, 1982, 1000, 1130, 2018

Product description

The merchandise under consideration is lithographed tinplate steel sheet, which is made to ASTM A623. This cold-rolled nonalloy steel sheet comes in thicknesses of 0.17 mm – 0.22 mm and widths of 710 mm – 1130 mm. According to your submission, electrolytically tinned steel coils produced in India, Turkey, or China are shipped to Colombia for further processing. There, they are cut-to-length and undergo lithographic printing before being palletized and shipped 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). Based upon the facts submitted, it is our determination that the lithographing process constitutes a substantial transformation of the tinplate sheet. Accordingly, the country of origin of the lithographed tinplate steel sheet will be Colombia. See Headquarters Ruling HQ 081333 dated April 20, 1990. The holding set forth above applies only to the specific factual situation and merchandise description as identified in

CBP rationale

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). Based upon the facts submitted, it is our determination that the lithographing process constitutes a substantial transformation of the tinplate sheet. Accordingly, the country of origin of the lithographed tinplate steel sheet will be Colombia. See Headquarters Ruling HQ 081333 dated April 20, 1990. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request.

Full text

N360018
April 2, 2026
OT:RR:NC:N5117
CATEGORY: Origin Robert Stang Husch Blackwell LLP 1801 Pennsylvania Ave., NW Suite 1000 Washington, DC 20006 RE: The country of origin of lithographed tinplate steel sheet Dear Mr. Stang: In your letter dated March 24, 2026, you requested a country of origin ruling on on behalf of your client, Steelforce Packaging US. The merchandise under consideration is lithographed tinplate steel sheet, which is made to ASTM A623. This cold-rolled nonalloy steel sheet comes in thicknesses of 0.17 mm – 0.22 mm and widths of 710 mm – 1130 mm. According to your submission, electrolytically tinned steel coils produced in India, Turkey, or China are shipped to Colombia for further processing. There, they are cut-to-length and undergo lithographic printing before being palletized and shipped 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). Based upon the facts submitted, it is our determination that the lithographing process constitutes a substantial transformation of the tinplate sheet. Accordingly, the country of origin of the lithographed tinplate steel sheet will be Colombia. See Headquarters Ruling HQ 081333 dated April 20, 1990. 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 [email protected].
Sincerely,
(for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division

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