Manufacture of basic iron and steel

Under MD 229 of 2025, manufacturing is a core Qualifying Activity. Forensic focus is on the 'Substantial Transformation' test. Auditors will verify that the iron/steel underwent a process that changed its tariff classification (HS Code) or added significant value through industrial processing rather than mere cutting or packaging.

Audit Red Flag

Mischaracterization of 'Trading in Steel' (Excluded Activity) as 'Manufacturing' (Qualifying Activity) without evidence of substantial transformation or chemical/physical change in the raw material.

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