The country of origin of a scissor jack

N348905 May 30, 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 a scissor jack Dear Ms. Xiao: In your letter dated May 12, 2025, you requested a country of origin ruling on behalf of your client, Torin (Thailand) Co., Ltd. The merchandise under consideration is identified as a scissor jack, model number THS02001, and is described as a screw-operated jack for lifting vehicles. It uses a hand crank assembly to convert rotational motion into linear motion. The crank drives a screw which causes the scissor arms to move closer together and raise a vehicle. The subject scissor lift is manufactured in Thailand using materials and components sourced from Thailand and China. A bearing, a handle assembly, and pins are sourced from China. The remaining components are produced in Thailand from steel bar, steel plate, and steel tubing. These include an upper arm assembly, lower arm assembly, base, screw rod, and more. The production process starts with creating an upper arm assembly and a lower arm assembly, components that will function as movable arms to raise the vehicle and support its weight. The upper arm assembly requires a subcomponent referred to as an upper support arm, which begins as a rough shape that is sheared from a steel sheet using a blanking process. Next, holes are punched, a toothed profile is created using a stamping die, and the formed sheet is stamped into the three-dimensional shape of the support arm. A pair of arms are riveted to a t-hook, which is a saddle that contacts the pinch welds of a vehicle. The steps to create the t-hook involve shearing a rough shape from a steel sheet, creating notched openings, and stamping the formed sheet into a three-dimensional shape. The lower arm assembly also requires a pair of lower support arms that are created following the same operational steps for the upper support arms. Since they form the bottom half of the scissor jack, these arms are mounted onto a base that is created from a steel plate in Thailand. Next, a worker creates the threaded screw rod, which involves cutting a round steel bar to length, forging one end into a ring for the handle assembly, and roll threading the length of the rod. The scissor lift also requires a bracket and nut, components that are used to unify the bearing, the arms, and the screw rod during final assembly. The bracket and nut are cut from round steel bar, machined to create either a flat or chamfered surface, then drilled and tapped to create female threads. Final assembly entails assembling the upper arm assembly, lower arm assembly, screw rod, bearing, nut, and bracket. Afterwards, the components are riveted together, greased is applied, labels are added, and the jack is packaged together with a Chinese-sourced handle assembly. When determining the country of origin for purposes of applying current trade remedies under Section 301, and additional duties, 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). Based upon your description of the manufacturing operations, we note that nearly all the components, including the upper assembly, lower assembly, screw rod, and more, are manufactured in Thailand. After processing, these critical components of the scissor jack emerge with a new name, character, and use, different from that possessed by the materials (e.g., steel tube, steel bars, and steel sheets) from which they were formed. Thus, based on the totality of the circumstances, the country of origin of the scissor jack, model number THS02001, 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, (for) Steven A. Mack Director National Commodity Specialist Division