The country of origin of hydraulic floor jacks

N347256 April 29, 2025 OT:RR:NC:N1:103 CATEGORY: Origin Helen Xiao Ernst & Young LLP 155 N Wacker Dr., #2000 Chicago, IL 60606 RE: The country of origin of hydraulic floor jacks Dear Ms. Xiao: In your letter dated March 31, 2025, you requested a country of origin ruling on behalf of your client, Torin (Thailand) Co., LTD. The merchandise under consideration involves three different models of hydraulic floor jacks, identified as a steel floor jack (model THF3-26XHB), an aluminum floor jack (model THA3-3XTB), and an aluminum-steel floor jack (model THA1.5-16CX). The steel floor jack is designed for heavy-duty industrial or automotive applications. It has a full steel construction and a maximum load capacity of three tons. The aluminum floor jack is designed for portability and uses aluminum components to reduce its overall weight. This model has a maximum load capacity of three tons. The aluminum-steel floor jack balances the strength of steel and the reduced weight of aluminum and has a maximum load capacity of one and a half tons. All three models will be manufactured at the same facility in Thailand using components and materials sourced from Thailand and China. The overall operational steps for all three models will be largely the same, starting with creating metal forms, turning them into component parts, and ending with final assembly. A separate scenario was presented for each model. Steel Floor Jack (THF3-26XHB) The steel hydraulic jack will be produced in Thailand using Chinese and Thai components. The process begins with creating the hydraulic power unit, which is described as the mechanism that provides the power to lift an object. The main components of the power unit include a base, top cap, cylinder, outer sleeve, piston rod, piston head, coupling connector, pump core, and pump body. The power unit’s base, top cap, and piston head are cast from raw steel scrap sourced from Thailand. Raw steel scrap is melted and further processed by spheroidization and inoculation treatments at a Thai foundry. Simultaneously, workers create and prepare sand molds, including the cores required for each casting. The liquid metal is poured into the sand mold and left to cool and solidify. The resultant castings are then machined, threaded, and further drilled to create oil passages for the base casting. The power unit’s cylinder is created from material lengths of seamless pipe while the outer sleeve is created from material lengths of welded pipe. The cylinder will have threads machined into both ends. The outer sleeve will have one chamfered end and a smooth inner surface with drilled holes on its opposite end. The piston rod is manufactured from material lengths of round steel bar that are cut to length, roughly ground to remove burrs or excess material, then subjected to further machining, including step turning and drilling. The pump core and pump body are sourced as finished components from China. The individual components are systematically combined with the power unit’s base, starting with the cylinder, outer sleeve, piston rod, top cap, and so forth. Sealing rings are added, bolts are used to secure the components in place, hydraulic fluid is added, and the power unit is load tested. The structural components, identified as the lifting arm assembly and frame assembly, are manufactured in Thailand from steel sheeting. Shapes are laser cut from the sheeting and then stamped, bent, or stretched into three-dimensional forms. Each assembly requires five discrete steel forms, which are then joined by robotic welding equipment to create either the lifting arm assembly or frame assembly. Additional components including the saddle assembly, high saddle assembly, cover plate, and handle assembly are also manufactured in Thailand either from metal sheets, welded steel pipe, or flat steel bar. The remaining components are sourced from China, and include the front wheels, rear caster assembly, handle socket, handle cover, protective pads, and assorted fasteners. Final assembly entails combining the power unit, lifting arm assembly, and frame assembly into the finished product. This is accomplished using straightforward assembly operations, described as securing the subassemblies using various fasteners and hardware, including cotter pins, clips, shafts, connecting rods, washers, nuts, and screws. Aluminum Jack (THA3-3XTB) The aluminum jack follows the same overall manufacturing processes as the steel hydraulic jack but uses an aluminum lifting arm assembly and an aluminum frame assembly. The lifting arm assembly is made from intermediate aluminum forms identified as a front block, back block, and side plates. The side plates are laser cut to shape from aluminum plates, then shot blasted and powder coated. The front block is cut to length from a three-dimensional aluminum bar profile. Holes are then drilled and tapped into the cut block. The back block arrives from China as an aluminum casting that requires CNC machining, drilling, and tapping in Thailand. The only non-aluminum component for the lifting arm assembly is a saddle base, which is created in Thailand from steel sheeting. Three metal forms are needed for the saddle base. The operational production steps are described as laser cutting shapes from steel sheeting, bending them to form, welding the resulting pieces into a unified part, and then shot blasting and powder coating the saddle base. The side plates, front block, back block, and saddle base are then assembled to create the lifting arm assembly. Two components are needed to create the aluminum frame assembly. The first component is identified as aluminum side plates, which are laser cut from aluminum plates and further treated by shot blasting and powder coating operations. The second component is a Chinese-sourced aluminum caster base. To create the frame assembly, the aluminum side plates and the aluminum caster base are assembled together with bolts and shafts. The aluminum lifting arm assembly and the aluminum frame assembly are subsequently incorporated during the final assembly process, which follows the same steps as described above for the steel hydraulic jack. Final assembly entails combining the power unit, lifting arm assembly, and frame assembly into the final product. This is accomplished using straightforward assembly operations, described as securing the subassemblies using various fasteners and hardware, including cotter pins, clips, shafts, connecting rods, washers, nuts, and screws. The completed unit will have a steel power unit, an aluminum lifting arm assembly, and an aluminum frame assembly. Aluminum-Steel Jack (THA1.5-16CX) The aluminum-steel jack follows the same manufacturing processes as the steel hydraulic jack but incorporates an aluminum frame assembly that is constructed using aluminum side plates and an aluminum caster base. The aluminum side plates are shapes that are laser cut from aluminum plates and further treated by shot blasting and powder coating. The aluminum caster base is sourced from China as a finished component. The aluminum frame assembly is created by assembling the aluminum side plates to the aluminum caster base and fixing them using bolts and shafts. The completed aluminum frame assembly is then combined with a steel lifting arm assembly, a hydraulic power unit, and the remaining components. Final assembly also follows the same process as described above for the steel hydraulic jack. Final assembly entails combining the power unit, lifting arm assembly, and frame assembly into the final product. This is accomplished using straightforward assembly operations, described as securing the subassemblies using various fasteners and hardware, including cotter pins, clips, shafts, connecting rods, washers, nuts, and screws. The completed unit will have a steel power unit, a steel lifting arm assembly, and an aluminum frame assembly. When determining the country of origin for purposes of applying current trade remedies under Section 301, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). CBP has held that whether an assembly process is sufficiently complex to rise to the level of a substantial transformation is determined upon consideration of all the operations that occur within that country, including any subassembly processes that take place in that country. Based upon your description of the manufacturing operations, we note that the primary assemblies (i.e., the hydraulic power unit, lifting arm assembly, and frame assembly) are manufactured in Thailand from common metal forms, metal pipes, and metal sheeting. Additional components, including the saddle assembly, cover assembly, foot pedal, handle assembly, and more, are also produced in Thailand. Collectively, the components are assembled to create an article, a hydraulic floor jack, which emerges from the process with a new name, character, and use, different from that possessed by the metal shapes prior to the processing. Thus, based on the totality of the circumstances, the country of origin of the steel floor jack (model THF3-26XHB), the aluminum floor jack (model THA3-3XTB), and the aluminum-steel floor jack (model THA1.5-16CX), will be Thailand. 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 Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Paul Huang at paul.huang@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division