The country of origin of ratchet tie-down straps

N355901 November 25, 2025 OT:RR:NC:||CEE010||:N1:104 CATEGORY: Origin Kefeng Jin Xuli Cargo Control PTE, LTD. 3 Phillip Street, #10-04, Royal Group Building Singapore 048693 RE: The country of origin of ratchet tie-down straps Dear Mr. Jin: In your letter dated November 10, 2025, you requested a country of origin ruling. The goods under consideration are five models of ratchet tie-downs, A820432, A821701, A914202, A843501, and A812801, whose function is to secure cargo or equipment during transport. Each ratchet tie-down consists of a gear and pawl style ratchet assembly, a short length of woven polyester tie down strap, a long length of woven polyester tie down strap, and two metal hooks of various types. The short strap is stitched at one end to a metal hook and attached at the other end to the ratchet. The long strap is stitched at one end to a metal hook, and the other end is left free to be fed into the slot of the ratchet during use. In your submission, you describe two scenarios in which the ratchet ties-downs will be produced from components sourced from both Vietnam and China. In scenario one, yarn spools are sourced from Vietnam-sourced and spun yarn. In Vietnam, the yarn spools are made into tie-down webbing using looms and cut into short and long lengths for each end of the tie-down. The hooks and ratchet assembly, both produced and assembled in China entirely from Chinese origin components, are then exported to Vietnam for final assembly operations. In Vietnam, the webbing short ends are sewn to a hook and one end of the ratchet assembly, and the tie-down long ends are sewn into a hook and inserted into the ratcheting portion of the ratchet assembly. Scenario two is like the first except that in scenario two final assembly operations, i.e., the sewing of the tie-down short ends to a hook and one end of the ratcheting assembly, and the sewing of the tie-down long ends into a hook and their insertion into the ratcheting portion of the ratchet assembly, are performed in China rather than Vietnam. 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 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 the 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-downs is imparted by the webbing straps. See HQ H305503, dated February 20, 2020, and New York Ruling Letters N343501, dated November 22, 2024, and N316901, dated February 4, 2021. Based on the information provided here, the woven straps are produced in Vietnam in both production scenarios. The straps maintain their name, character, and use after being sewn to and assembled together with the Chinese-origin ratchet assembly and hooks in either Vietnam or China. Therefore, the country of origin of the complete ratchet tie-downs, models A820432, A821701, A914202, A843501, and A812801, for both production scenarios, 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division