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On smogon it says that it is in untiered

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I'm pretty sure this is because it's impossible to obtain a level 5 Meltan. You'll probably get a better answer if you ask here. https://www.smogon.com/forums/forums/little-cup.528/
It is possible to get an under level 5 Meltan. You need a really low CP Meltan in pokemon go.
Can confirm, you can even get a level 1 Meltan if you wanted

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It's simple: Meltan would never be in LC because it doesn't evolve, at least in the main series games. Meltan evolves in Pokemon GO, and in fact, it's pretty much the only way you can get Melmetal legitimately. But in gens 7 and 8, you can't evolve it, which is the reason that it's not in the LC tier.

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