The country of origin of a Measuring Wheel

N304231 May 28, 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 a Measuring Wheel Dear Mr. Fiebig: This is in response to your letter dated May 1, 2019, on behalf of Komelon USA Corporation, requesting a ruling on the country of origin of a measuring wheel assembled in China. A fully assembled measuring wheel is a hand-held linear measuring instrument comprised of a wheel and counter head. As the wheel is rolled over a surface, the attached counter head measures the distance between two points. You have stated that the counter head is produced in Japan by a Japanese supplier. The counter head is then shipped from Japan to China, where final assembly of the measuring wheel is undertaken. The Chinese origin parts include the follow: Arm assembly Clamp Frame assembly Counter bar Wheel Assembly Stand plates Stand Fasteners (nuts, bolts, washers) 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. In applying the substantial transformation test, each case must be decided on its own facts. The imported article is a measuring device whose essential character and function are imparted by the counter head. The additional parts added in China do not change that character. Consequently, the assembly process in China does not result in a new product having a new character or use. Therefore, the good remains a product of the Japan. 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division