The country of origin of a fiberglass measuring reel

N348790 May 22, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Andre Fiebig Quarles & Brady 300 N. LaSalle, Suite 5200 Chicago, IL 60660 RE: The country of origin of a fiberglass measuring reel Dear Mr. Fiebig: In your letter dated May 8, 2025, on behalf of your client, Komelon USA Corporation, you requested a country of origin ruling on a fiberglass measuring reel. Descriptive literature was provided for our review. The item under consideration is described as a fiberglass measuring reel, which is a device used by tradespeople, inspectors, contractors, homeowners, and many other types of consumers to measure distances between two points by use of a printed fiberglass tape. The device is designed to be staked to the ground and then pulled to the required length. Alternatively, the user can attach the ring-hook to the beginning point to be measured and then the whole unit pulled to the desired length. To lock the tape in place, the user would flip the handle up into the reel which then prevents the tape from moving. There are slightly different versions of the reel, but each one has measurements printed along both sides of the tape. Some models have imperial units of measure markings only and other models are marked with both imperial and metric units of measure. The measuring reels come in three different lengths: 100, 200, and 300-foot lengths. The fiberglass measurement strip is flexible, which permits one to measure around curves or corners. The fiberglass measuring tapes are produced, printed, cut, and rolled in the Republic of Korea. The bulk rolls are then shipped on a spool from the Republic of Korea to Vietnam. In Vietnam, the final tape reel is assembled with the remaining Vietnamese components which include the plastic case, handle, ground stake, ring hook, lever drum, washer, rubber wings, bobbin, brush, bit, and screws. The fiberglass tape makes up over half of the overall cost of the finished article. The additional components are wrapped around the Korean fiberglass tape and the ring hook, ground stake, handle, bobbin, brush, and outer casings are attached by screws, which lock the components in place. The finished fiberglass tape reel is then packaged for retail sale before export to the United States. When determining the country of origin, 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). Regarding the origin of the completed fiberglass measuring reel, the additional parts added in Vietnam do not change the essential function of the fiberglass printed reel. Consequently, the simple assembly process in Vietnam, which predominantly involves placing, snapping, and screwing components into place, 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 Republic of Korea, which is where the fiberglass measuring tape is manufactured. 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division