![]() The NAFTA is implemented in GN 12, HTSUS. ![]() ISSUE: Whether the copper cathode sheets are eligible for preferential tariff treatment under the NAFTA. These anodes will then be used in Glencore’s ordinary course of business producing refined copper cathode sheets in the manufacturing process described above. This will result in new anodes that Glencore will treat as self-produced, non-originating materials for purposes of the NAFTA. When the spent copper anodes are placed in the re-melt furnace, Glencore will also add off-grade copper cathodes classified in heading 7403, HTSUS from non-NAFTA sources along with other high-copper-content materials of unknown origin classified in various headings of Chapter 74, HTSUS. These anodes are processed in the refinery’s re-melt furnace to produce new copper anodes for use in the typical manufacturing process. In addition to finished copper cathode sheets, this manufacturing process also creates “spent” or “partially-consumed” anodes classified in heading 7404, HTSUS. After removal from the electro-refining tank, the finished copper cathode sheets are removed from the steel mother blanks and are ready for sale to customers after they are washed and inspected. The copper anodes stay in the refining tank for 21 days, and the stainless steel blanks (with new copper cathode sheets) are removed and replaced every seven days. The pure copper dissolved in the solution is attracted to and deposited onto the stainless steel blank, forming a pure copper cathode sheet by process of electrolysis. The sulfuric acid begins to dissolve the copper anodes, and an electric current activates the refining process. Next, stainless steel “mother blank” sheets are placed in the tank between each copper anode. First, both originating and non-originating copper anodes classified in heading 7402, HTSUS, are submerged in a tank containing a sulfuric-acid solution. Glencore’s typical manufacturing process for copper cathode sheets includes the following steps. The products at issue are refined copper cathode sheets, classified in heading 7403, Harmonized Tariff Schedule of the United States (“HTSUS”), that Glencore will manufacture at this refinery. FACTS: Your client Glencore Canada Corporation operates a copper refinery located in Montreal, Quebec, Canada. Rucker: This is in response to your letter dated October 28, 2015, and referencing your letter dated September 14, 2015, concerning Glencore’s request for a ruling on the eligibility of certain copper cathode sheets for preferential tariff treatment under the North American Free Trade Agreement (“NAFTA”). Re:Ğligibility of Copper Cathode Sheets for NAFTA Duty Preference Dear Mr. Rucker Drinker Biddle & Reath LLP 191 North Wacker Dr., Suite 3700 Chicago, IL 60606-1698 In the construction industry, it is used for various pipes, pipe fittings, decorative devices, etc.OT:RR:CTF:VS H270640 RMC William R. For every 1 million rounds of bullets produced, 13-14 tons of copper are needed.ĥ. In the national defense industry, it is used to manufacture bullets, shells, gun parts and so on. It is widely used in manufacturing vacuum, distillation and brewing pots in chemical industry.Ĥ. In the manufacture of machinery and transport vehicles, it is used to manufacture industrial valves and accessories, instruments, sliding bearings, moulds, heat exchangers and pumps, etc.ģ. It is used for winding resistance of various cables and wires, motors and transformers, switches and printed circuit boards, etc.Ģ. Copper is most widely used and used in the electric and electronic industries, accounting for more than half of the total consumption. It is second only to aluminum in the consumption of non-ferrous metal materials in China.ġ. It is widely used in electrical, light industry, machinery manufacturing, construction industry, national defense industry and other fields. Electrolytic copper is a non-ferrous metal closely related to human beings.
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