The country of origin of golf club heads

N350113 July 1, 2025 OT:RR:NC:N3:356 CATEGORY: Country of Origin Jeffrey Sims Seyfarth Shaw LLP 30344 Rhone Drive Rancho Palos Verdes, CA 90275 RE: The country of origin of golf club heads Dear Mr. Sims: In your letter dated June 11, 2025, you requested a country of origin ruling on behalf of your client, L.A. Golf LLC. The goods under consideration are titanium golf club heads. A description of the manufacturing processes for these goods was submitted for our review. The manufacturing processes are as follows: Raw materials, including titanium, are sourced from Taiwan and exported to Vietnam. In Vietnam: Wax tree assemblies for the golf club heads are produced through wax injection and molding operations and assembled into casting trees. Ceramic shelling is affixed around the wax tree assemblies through repeated coating, dipping, and drying. The wax tree assemblies are placed in a furnace to burn out the wax from the ceramic shell. The now-ceramic trees are heated in a high temperature furnace, after which molten titanium metal is poured into the trees. After cooling, the ceramic is separated from the metal castings and excess material is removed. The golf club heads are exported from Vietnam to China. Tip adapters are manufactured in Taiwan and exported to China. In China: The golf club head bodies are ground. The golf club head faces are welded onto the bodies, and the faces are then ground, polished, and engraved. The tip adapters are attached. The golf club heads are coated, screws are attached, and logos are lasered to the faces. The golf club heads are packaged for shipment and exported to the United States. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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. 1992). You suggest that the country of origin of the golf club heads is Vietnam. We agree. It is this office’s opinion that the manufacturing operations performed in Vietnam to produce the golf club heads impart the essence of these articles. The above-described casting processes used to transform the raw materials into the final shape of the golf club heads take place in Vietnam. The finishing processes performed in China enhance the aesthetics of the casted golf club heads. In our view, these items are not substantially transformed by the processes performed in China. Based on the facts presented, the country of origin of the titanium golf club heads is Vietnam. 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, contact National Import Specialist Maryalice Nowak at maryalice.nowak@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division