The country of origin of ICR 1001

N361707June 16, 2026CLA-2-38:OT:RR:NC:N3:135
CATEGORY: OriginDebby AndersonOdyssey International Services305 Bridgepoint DriveSouth St Paul, MN 55075RE: The country of origin of ICR 1001Dear Ms. Anderson:In your letter dated
May 21, 2026
, on behalf of your client, Chevron Lummus Global, you requested a tariffclassification and country of origin determination ruling. Additional information was provided via emaildated June 1 and June 11, 2026. The classification of the product will be addressed in a separatecorrespondence.ICR 1001 is described as a hydroprocessing catalyst in the form of shaped solid extrudates. It contains NiMoW-001(CAS 1351378-24-9), Cellosize, and ethylene glycol. Under hydrogen t elevated temperature aand pressure in refinery operation, ICR 1001 facilitates critical hydroprocessing reactions, such ashydrodesulfurization and hydrodenitrogenation.These reactions are essential for removing sulfur and nitrogen compounds and upgrading hydrocarbon feedstocks for clean fuel production in a refinery.The manufacturing process begins with the combination of Chinese-origin NiMoW-001 powder,Germany-origin Cellosize or Methocel (CAS number 9004-65-3) from an undisclosed country, SouthKorea-origin ethylene glycol, and water. This blend is mixed to create a wet paste, which is then pressed through an extruder equipped with die buttons featuring proprietary asymmetric quadrilateral-shaped holes. As the mixture passes through, it forms long, wet noodles that are subsequently dried at 300 °F in a vibratingbelt dryer.Once dried, the noodles are routed through sizing equipment and cut into precise dimensions required for thefinished catalyst. The final extrudates have an asymmetric quadrilateral shape, with diameters ranging from1.5 to 3.0 mm and lengths between 3 to 8 mm. Among their notable physical properties is a crush strength exceeding 5 lb/mm, underscoring their durability and reliability during refinery operations.The entire manufacturing process takes place in South Korea. After production, ICR 1001 is ready for shipment and immediate use in refinery operations.
You explain that NiMoW-001 functions as the catalytically active metal precursor phase incorporated intoICR 1001 hydroprocessing catalysts for petroleum refining applications. Cellosize or Methocel is organic extrusion aid used to improve rheology and plasticity during extrusion. Its use increases extrusion rate, improves the crush strength, adjusts particle density and porosity of the finished ICR 1001. Ethylene glycol functions as an extrusion aid as well to control behaviors and moisture retention, which helps improve crushstrength and control particle density. The 300 °F vibrating belt dryer operation is a drying step intended primarily to remove free and physically adsorbed water from the wet extrudates.You claim that the ICR 1001 manufacturing process converts the raw materials, such as NiMoW-001 andCellosize powders, into a formed catalyst body suitable for refinery hydroprocessing reactor loading andindustrial refining use. The process changes the physical form, pore structure, and mechanical properties while preserving the intended catalytic function of the NiMoW-001 component.Physical changes includes (a) transformation from 10 micron dry powder to extrudate particles in asymmetricquadrilateral shape with diameters ranging from 1.5 to 3.0 mm and lengths between 3 to 8 mm, (2) extrudateparticle having crush strength greater than 5 lb/mm, (3) unique pore structure, with well distributed macro-(>50 nm) and meso-pores (2-50 nm), generated during peptization in the mixer, extrusion and drying.Crush strength results from NiMoW-001 particle interactions with Cellosize and ethylene glycol, as well as fromextrusion and drying. Size is controlled by adjusting moisture levels during extrusion and by using cutters and screening after drying.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 asubstantial 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).In determining whether a substantial transformation occurs in the manufacture of products from chemicals,Customs has consistently examined whether a chemical reaction occurs when two chemicals are mixed in theproduction of the final article. In this instance, Cellosize and ethylene glycol are added to NiMoW-001 asextrusion aids to form a wet paste with water. The paste is then extruded, dried, sized, and cut to produce thefinal product, ICR 1001.The drying process primarily removes water, while Cellosize and ethylene glycol remain in ICR 1001. Thus, ICR 1001 contains NiMoW-001, Cellosize, and ethylene glycol. Although the process alters the physical form, pore structure, and mechanical properties of the NiMoW-001 powder, nochemical reaction occurs during manufacturing. The Chinese-origin NiMoW-001 powder does not undergo substantial transformation as a result of the operations that occur in South Korea, and its intended catalyticfunction and use remain unchanged. Therefore, the country of origin for ICR 1001 is China. The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Fei Chen at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division