The country of origin of fishing rods

N353511 October 7, 2025 OT:RR:NC:N3:356 CATEGORY: Origin Ms. Kerry Wang Braumiller Law Group PLLC 5220 Spring Valley Road, Suite 200 Dallas, TX 75254 RE: The country of origin of fishing rods Dear Ms. Wang: In your letter dated September 9, 2025, on behalf of your client, Composite Forge, LLC, you requested a country of origin ruling on the Centra series of fishing rods for purposes of country of origin marking and the application of trade remedy and additional duties. Photographs and drawings of representative models of the rods and their components, bills of materials, and a description of the manufacturing processes used to produce the rods were included with your inquiry. The manufacturing operations are as follows: Rod blanks are manufactured in the United States to required specifications (length, diameter, etc.) and exported to China. Handles, reel seats, line guides, and hook keepers are manufactured in China. In China, the line guides are thread-wrapped onto the rod blanks, and the thread wraps are encapsulated with epoxy. Also in China, the handles, reel seats, and hook keepers are assembled onto the rod blanks. The finished rods are exported to the United States. 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” 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 the marking laws and regulations. U.S. Customs and Border Protection (CBP) has previously held that the component of a fishing rod that imparts its essential character is the rod blank, and that the assembly of fishing rod components onto a rod blank does not result in a substantial transformation of the rod blank (see Headquarters Ruling Letter (HQ) H560115, dated March 7, 1997). In the scenario you describe, the rod blanks are produced in the United States. Therefore, pursuant to HQ 560115, we find that the country of origin of the Centra series of fishing rods, as produced under the circumstances you describe, is the United States. Accordingly, at the time of entry, the fishing rods need not be marked with their country of origin and they will not be subject to trade remedy or other duties. 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 Maryalice Nowak at maryalice.nowak@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division