November 06, 2009
U.S. Imports of Scrap Metal Require Mill Test Certificate

In response to an internal advice request from U.S. Customs and Border Protection (CBP) Pembina Service Port, CBP has issued a letter stating that imports of scrap metal require a Mill Test Certificate. 

The CBP advisory letter pertains to the application of Section 141.89, CBP Regulations (19 C.F.R. §141.89).  At issue are iron and steel classifiable in chapter 72, Harmonized Tariff Schedule of the United States (HTSUS), and articles of iron or steel classifiable under heading 7301, HTSUS to heading 7307, HTSUS.  CBP’s response states that because such items are used and may be quite old, importers frequently do not enter them with a Mill Analysis or Mill Test Certificate.  A Mill Test Certificate (or Mill Analysis or Mill Test Report) is a certified quality control document from a testing facility that outlines the chemical makeup and physical properties of materials required to meet certain specifications.  Usually these documents are provided by a steel foundry or manufacturer that tests the materials they produce, in which case the Mill Test Certificate also provides the country of origin of the imported merchandise.

The CBP advisory states that the requirements of 19 C.F.R. §141.89 apply to both new and used merchandise.  Importers of steel and iron merchandise covered by the regulation must provide, with the entry documentation, a statement of the percentages by weight or carbon and any metallic elements contained in the articles, in the form of a Mill Analysis or Mill Test Certificate.

The complete text of CBP’s response to the internal advice request from U.S. Customs and Border Protection (CBP) Pembina Service Port can be accessed at this URL:
http://rulings.cbp.gov/index.asp?ru=h068635&qu=h068635&vw=detail

For more information, please contact your local FedEx Trade Networks Transport & Brokerage office. For a complete list of office locations go to http://www.ftn.fedex.com/locations/index.html.