The country of origin of a bottle jack

N351580 August 14, 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 bottle jack Dear Ms. Xiao: In your letter dated July 22, 2025, you requested a country of origin ruling on behalf of your client, Torin (Thailand) Co., Ltd. The subject merchandise is a hydraulic bottle jack, model number THB12-4, and is described as a vertical hydraulic jack that utilizes a high-pressure cylinder and pump mechanism to lift objects. It is used during automotive repair as well as in industrial, farming, and construction applications. In New York Ruling Letter N344692, dated January 10, 2025, we considered a different production process for the subject bottle jack. The production scenario discussed in that ruling has been discontinued. In the current manufacturing scenario, raw material, steel pipes, and steel bars will be manufactured into a base assembly, ram assembly, pump plunger assembly, handle assembly, and other components in Thailand. Additional components will be sourced from China, including a handle socket assembly, a relief valve, a safety valve, and miscellaneous items including screws, snap rings, O-rings, washers, plugs, ball bearings, springs, and pins. The factory in Thailand is divided into multiple sections. The first section is dedicated to creating the ram assembly and its subcomponents, which include a piston rod, a piston head, a screw sleeve, and an adjustable top screw. The piston rod is created from steel pipe that is cut to length, drilled to create process holes, and then machined on both ends using a step turning process. The piston head is created using a sand-casting process then machined to its final tolerances. Next, the subcomponents are assembled. A Chinese-sourced threaded screw sleeve is pressed into one end of the piston rod, an adjustable top screw is threaded into the sleeve, and the piston head is pressed into the opposite end of the piston rod. The next section is dedicated to manufacturing the remaining components for the bottle jack, including a base, a cylinder body, an outer sleeve, a pump body, and a pump plunger. This starts with using a hot forging process to create a rough form for the base. The base is finished by milling end faces for the safety and return valves, machining grooves for oil flow, drilling holes for the oil plug and process holes, and tapping the holes for the valves. Separately, the cylinder body and the outer sleeve are created using operational steps that include cutting steel pipes to length, machining grooves, creating chamfered edges, drilling holes, and more. The outer sleeve has a rounded top which is created by partially closing one end of a pipe using a stamping process. A pump body and pump plunger assembly are created from round steel bars, which are cut to size, machined to create chamfered ends and grooves, then drilled. For the pump plunger, a seal kit is also pre-installed. Final assembly requires welding the cylinder to the base, welding the outer sleeve to the base, welding the pump body to the base, installing the safety and release valves, installing the pump plunger assembly, installing the ram assembly, adding oil, and attaching the handle assembly. Lastly, the bottle jack is painted and packaged for export. 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 ram assembly, base assembly, cylinder body, sleeves, pump body, and pump plunger, and more, are manufactured in Thailand. After processing, these critical components of the bottle jack emerge with a new name, character, and use, different from that possessed by the materials (e.g., steel pipes, steel bars, and raw materials) from which they were formed. Thus, based on the totality of the circumstances, the country of origin of the bottle jack, model number THB12-4, 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) James Forkan Acting Director National Commodity Specialist Division