The country of origin of bottle jacks

N355131 November 10, 2025 OT:RR:NC:N1:103 CATEGORY: Origin Gloria Gao JACKUP International Company Limited Room 1703, Yishi Mansion, No. 95 Zhongshan Bei Road Nanjing City, Jiangsu Prov. 210009 China RE: The country of origin of bottle jacks Dear Ms. Gao: In your letter dated October 21, 2025, you requested a country of origin ruling. The merchandise under consideration are hydraulic bottle jacks and are described as tools with a bottle-like shape for lifting heavy loads. Five model numbers are part of this request: a 2-ton hydraulic bottle jack, model number JA-BT-002T; a 6-ton hydraulic bottle jack, model number JA-BT-006T; an 8-ton hydraulic bottle jack, model number JA-BT-008T; a 12-ton hydraulic bottle jack, model number JA-BT-1012T, and a 20-ton hydraulic bottle jack, model number JA-BT-1020T. All of the bottle jacks will be produced in Thailand using the same scenario. All of the bottle jacks will be assembled in Thailand using components sourced exclusively from China, including an oil cylinder, pump base, piston rod, handle, handle socket, saddle ram, valves, steel balls, and miscellaneous hardware such as washers, nuts, screws, pins, and O-rings. First, ultrasonic cleaning machines are used to remove any contaminants from the components. Afterwards, the pump base is machined to its final tolerances and holes are drilled into the oil cylinder. At the next station, the pump base, oil cylinder, and piston rod are welded together to form the main structure of the jack. To this assembly, the saddle ram along with springs, gaskets, bolts, pins, etc., are incrementally installed using operational steps described as inserting then tightening the components using torque wrenches. Lastly, the bottle jack is tested, 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). CBP has held that whether an assembly process is sufficiently complex to rise to the level of a substantial transformation is determined upon consideration of all the operations that occur within that country, including any subassembly processes that take place in that country. Based on your description of the manufacturing operations, we note that all of the components are sourced from China as finished components, requiring only assembly operations in Thailand. Thus, based on the totality of the circumstances, the country of origin of the bottle jacks (model numbers JA-BT-002T, JA-BT-006T, JA-BT-008T, JA-BT-1012T, and JA-BT-1020T), will be China. 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division