8113.00.00: the tungsten hard scrap code the export order does not name

The 2026-08-27 allocation order restricts the export of tungsten waste and scrap, which it names by one Schedule B line, 8101.97.00.00. It does not name 8113.00.00, the line that two US tungsten producers had told Commerce carries tungsten hard scrap.

What Plansee USA told Commerce

Plansee USA filed comment 0164 on docket BIS-2025-0025 on 2025-05-16, signed by its president and CEO. Its first numbered request asks that a code be added to the Critical Minerals List and exempted from reciprocal tariffs for every country except China. In that request it says the code

“is used for Tungsten hard scrap”

The code is 8113.00.00. A US producer told Commerce in writing which tariff line carries its hard scrap.

Hard scrap is used carbide: inserts, tips, drill bits and wear parts. It is the high-value part of the tungsten scrap trade. Soft scrap is sludge, swarf and powder.

Kennametal’s filing on the same docket, comment 0176, prints the same heading (cermets and articles thereof, including waste and scrap) and asks that it stay restricted.

What the order names

The rule restricts four Schedule B lines:

Schedule B	What the rule says it is
8101.97.00.00	Tungsten waste and scrap
8549.13.00.00	Battery waste and scrap, sorted by chemical type, without lead, cadmium or mercury
8549.14.00.00	Battery waste and scrap, unsorted, without lead, cadmium or mercury
8549.19.00.00	Battery waste and scrap, other

8113.00.00 is not on the list, and the word “cermets” does not appear in the rule. The rule defines black mass in words, but it identifies tungsten waste and scrap only by its Schedule B line.

How big the unnamed code is

US exports under both codes in 2025, from UN Comtrade:

2025 US exports	Tonnes	Value
8101.97, restricted from 2026-08-27	2,199.6	$28.98M
8113.00, not restricted	1,911.3	$91.72M

Both grew against 2024. By weight, the restricted code rose 14.1 percent and the unrestricted code 24.8 percent. 8113.00 also carries finished cermet articles, so not all of its $91.72M is scrap.

Why the dates matter

A firm whose material moves under a line the order does not name has a position it can check today. The order runs to 2027-08-27, contains a clause that lets BIS add materials, and takes comments until 2026-11-04. The exception route and the comment deadline have their own page.

This page does not say how any shipment should be classified.