The country of origin of a power carpet stretcher

N348764 May 29, 2025 OT:RR:NC:N1:104 CATEGORY: Origin Fu Yang One Rich Flooring & Carpet Co., Ltd. 4 F.-2, No. 374, Sec. 1, Wenhua 3rd Rd., Linkou Dist., New Taipei City 244240 Taiwan RE: The country of origin of a power carpet stretcher Dear Fu Yang: In your letter dated May 8, 2025, you requested a country of origin ruling. The product in question, the Junior Power Carpet Stretcher, is assembled in Taiwan from both Taiwanese and Chinese origin components. The Junior Power Carpet Stretcher tool tensions carpeting in rooms. The tool features a head with adjustable sharp pins or prongs that grip the carpet, seven extension tubes for spanning the room, a lever handle mechanism, and a tail block that braces against a wall, providing a stable base for applying tension with the lever mechanism. The product is packaged in specially shaped plastic cases for holding the components. In operation, the tool is configured with the necessary number of extension tubes to span the room, and the head of the tool is placed on the carpet near the wall. Pushing the handle down causes the pins on the tool’s head to dig into the carpet while pulling the carpet forward and removing the slack. The tool is then manually shifted over to another section of carpet and the operation is repeated until wrinkles are removed and a tight fit is achieved. The Junior Power Carpet Stretcher is assembled in Taiwan from Chinese and Taiwanese origin components. Key components such as the head with pins, sliding base and fixed tube, and multiple metal extension tube sections to facilitate stretching, are sourced from China in unassembled form. Other Chinese components include a liner tube, handle shaft bushings, a pin shaft, a threaded shaft, a connection plate for fastening the handle to the extension connector, and positioning springs. These finished Chinese components are then shipped to Taiwan for assembly with Taiwanese-origin components including the lever handle and end cap, handle connection base, and a tail block. In Taiwan, the tool undergoes a multi-step assembly process consisting of component alignment, calibration, axle fitting, and assembly of the various components using simple fasteners such as screws, nuts, bolts, and washers. Regarding your request for the appropriate country of origin for the finished Junior Power Carpet Stretcher, 19 C.F.R. § 134.1(b) provides that country of origin means the country of manufacture, production, or growth of any article of foreign origin entering the United States. Any additional work or material added to an article in another country must effect a substantial transformation to render such other country the “country of origin.” 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, 69 C.C.P.A. 151 (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). 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 simple or minimal will generally not result in a substantial transformation. We find that the assembly operations performed in Taiwan do not constitute a substantial transformation of the Chinese components. These assembly operations consist mainly of simple press-fitting, mounting, and adjustment of components. While the Taiwanese-sourced handle provides leverage, it is but one of several components — the majority of which are Chinese origin — that work together to stretch or tension the carpet across an entire room. For example, the tool head grips the carpet while the sliding base and fixed tube, and multiple extension tubes, work together to allow the tool to pull and stretch the carpet. In this regard, we disagree with your assertion that these Chinese components are mere “support structures” of the Junior Power Carpet Stretcher. As the simple assembly operations in Taiwan do not result in the Chinese components acquiring a new name, character, or use, a substantial transformation has not occurred. Therefore, the country of origin of the imported Junior Power Carpet Stretcher will be China. 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 Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division