The Country of Origin of Paris Truck Company Skateboard Trucks

N315107 October 23, 2020 OT: RR: NC: N4:424 CATEGORY: Country of Origin Mr. Neil Helfand Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP 599 Lexington Ave FL 36 New York, NY 10022 RE: The Country of Origin of Paris Truck Company Skateboard Trucks Dear Mr. Helfand: This is in response to your letter dated October 7, 2020, requesting a country of origin determination on skateboard trucks, on behalf of your client, Paris Truck Company of Lakeside, California. A description of the manufacturing processes was submitted for our review. Paris Truck Company is a manufacturer and importer of skateboard trucks, which are used to attach the skateboard wheels to the skateboard deck/board. The individual parts that comprise the finished product include: a urethane pivot cup, kingpin washers, urethane bushings, axle/kingpin nuts, a kingpin, a baseplate and a hanger with axle. According to the information stated in your letter, the principle components to the skateboard deck are the hangers (axles) and the baseplates that connect the wheels to the skateboard deck. You also state that aluminum ingots sourced from both Taiwan and Dubai will be melted in Taiwan at 1300 degrees Fahrenheit and cast into steel molds to form the hangers (axles) and baseplates for the trucks. Once the cast truck parts are cooled and separated from the castings, each part will be ground, polished and the holes drilled where needed. This entire process takes place in Taiwan. The baseplate and hanger will subsequently be transported to China for assembly into skateboard trucks using Chinese made top and bottom bushings, washers, pivot cups, nuts and kingpin components. Upon final assembly, the skateboard trucks will be imported into the United States. With regard to your request for the appropriate country of origin of the aforementioned skateboards, 19 C.F.R. § 134.1(b) provides in pertinent part as follows: Country of origin means 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.” A substantial transformation occurs when articles lose their identity and become articles having a new name, character, or use. A “complex or meaningful” assembly operation may result in a substantial transformation while a “minimal, simple, assembly-type operation” ordinarily will not. In order to determine whether a substantial transformation occurs when components of various origins are assembled into completed products, all factors such as the components used to create the product and manufacturing processes that these components undergo are considered in order to determine whether a product with a new name, character and use has been produced. No one factor is decisive, and assembly operations that are minimal will generally not result in a substantial transformation. In this instance, it is this office’s opinion that the manufacturing operations of the skateboard components, specifically the skateboard decks and skateboard trucks in Taiwan, which provide the essence of these articles. These items are not substantially changed by either the addition of the Chinese components, or the minor assembly operations performed in China. Therefore, based on the facts presented in this case, the country of origin of the Paris Truck Company’s skateboard trucks is Taiwan. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 177). The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in 19 CFR 177.9(b)(1). In the event that the facts or merchandise are modified in any way, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and you should resubmit for a new ruling in accordance with 19 CFR 177.2. 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 Roseanne Murphy at roseanne.j.murphy@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division