The country of origin of Tape Measures

N302427 February 7, 2019 MAR-2 OT:RR:NC:N1:105 CATEGORY: Origin Mr. Andre Fiebig, Esq. Quarles & Brady LLP 300 N. LaSalle Street Suite 4000 Chicago, IL 60654-3406 RE: The country of origin of Tape Measures Dear Mr. Fiebig: This is in response to your letter dated December 12, 2018, on behalf of Komelon USA Corporation, requesting a ruling on the country of origin of tape measures assembled in China. Each tape measure consists of a steel spring, a steel printed tape measure and other various parts such as a plastic case, bobbin, hook and belt clip. You have stated that the raw steel used to produce the spring and printed tape measure is procured in Japan and shipped to South Korea. In South Korea, it is annealed and slit to achieve the specific thickness and width of the tape measure and spring. The tape measure is then painted and printed with the measuring graduations. The printed tape measure and spring are subsequently shipped from Korea to China. In China, the printed tape measure and spring are assembled together with the Chinese sourced plastic case, bobbin, hook and belt clip. The complete tape measure is then exported from South Korea to the United States. The "country of origin" is defined in 19 CFR 134.1(b) as "the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the 'country of origin' within the meaning of this part. With respect to the complete tape measures, the additional parts added in China do not change the essential function of the steel printed tape measure. Consequently, the assembly process in China does not result in a new product having a distinctive name, character or use. Therefore, in our opinion, the good remains a product of the South Korea. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Anthony E. Grossi at anthony.e.grossi@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division