The country of origin of ratchet tie downs

N351767 August 7, 2025 OT:RR:NC:N1:104 CATEGORY: Origin Nora Li Finehau Viet Nam Produce Company Limited Lot CN4.1 Tien Lang Town Industrial Zone, Tien Lang Commune, Hai Phong City 05206 Vietnam RE: The country of origin of ratchet tie downs Dear Ms. Li: In your letter dated July 29, 2025, you requested a country of origin ruling. The products in question are 1 in. x 12 ft. Reflective Ratchet Tie Downs, SKU no. 2247012, imported fully assembled in a retail package of 4 ratchet tie downs. The ratchet tie downs will be produced in two countries, China and Vietnam. Your submission included a production flowchart, a description of the processing, and a short video showing the assembly of Chinese ratchet assembly components in Vietnam. The ratchet tie downs are used to secure cargo and loads during transportation. They consist of a gear and pawl ratchet assembly, a short and long length of woven polyester webbing strap, and metal end fittings comprised of two metal “S” hooks or flat hooks. The ratchet assembly is comprised of a round gear with several teeth, two spring-loaded pawls that interact with the gear teeth, a center shaft, and a ratcheting handle used to tension the strap. In Vietnam, spools of Chinese-sourced and spun polyester yarn are made into tie-down webbing using a webbing machine. In Vietnam, the webbing is then flattened and stretched using a high-temperature calendaring/stretching machine. Reflective strips are then heat-transferred onto the center of the webbing using a heat transfer machine. The webbing is then cut to prescribed lengths. Sewing machines are used to stitch the webbing with the Chinese-origin hooks and to sew on fabric and warning labels. Next, Vietnam-sourced polypropylene (PP) plastic pellets are fed into injection molding machines to produce the ratchet handle and release tab, and to produce the packaging case. Chinese-origin metal ratchet assembly hardware parts are assembled in Vietnam by hand riveting and simple hand assembly. The completed ratchet tie downs are then secured to the plastic packaging case with tie wire and exported to the U.S. in cartons. The “country of origin” is defined in Section 134.1(b) of the U.S. Customs and Border Protection (CBP) Regulations (19 CFR 134(b)) as “the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the ‘country of origin’ within the meaning of this part.” The substantial transformation test is also used to determine the country of origin for purposes of Section 301 measures and other duties. 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. 1993). CBP has determined in similar country of origin scenarios that the essential character of like ratchet tie-down straps are imparted by the webbing straps, as purchasers are buying the tie down straps to secure their cargo. See HQ H305503, dated Feb. 20, 2020, and New York Ruling Letters N343501, dated Nov. 22, 2024, and N316901, dated Feb. 4, 2021. In this case, the straps are produced in Vietnam from Chinese polyester yarn and maintain their name, character, and use as tie down straps after simple assembly in Vietnam with the Chinese origin ratchet components. Accordingly, the country of origin of the complete ratchet tie down straps, will be 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, please contact National Import Specialist Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division