The country of origin of a track shoe

N357106 January 7, 2026 OT:RR:NC:N1:103 CATEGORY: Origin David Forgue Barnes, Richardson & Colburn, LLP 303 East Wacker Drive, Suite 305 Chicago, IL 60601 RE: The country of origin of a track shoe Dear Mr. Forgue: In your letter dated December 17, 2025, you requested a country of origin ruling on behalf of your client, Thyssenkrupp Berco of America. The merchandise under consideration is identified as a track shoe, which is a metal plate used in the track system of heavy machinery such as bulldozers and excavators. When installed, the plates contact the ground and are designed to increase traction, distribute the weight of the machine for stability, and protect the track system. Steel bar profiles that range from twenty to thirty feet in length are sourced from the United Kingdom and shipped to Italy. In Italy, the steel bar profiles are cut into one- to two-foot lengths. The next two steps are described as creating notches (or articulation windows) into the cut bars and drilling holes for mud and bolt holes. Afterwards, the track shoe is heat treated using austenitizing, quenching, and tempering processes. Lastly, the track shoe is shot blasted, straightened, 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). In viewing the information provided with your submission, it is our view that the operational steps that occur in Italy transform the steel bar profiles into track shoes. The processes substantially transform the steel profiles into a new and different article of commerce with a name, character, and use distinct from the exported article sourced from the United Kingdom. As such, and based on the totality of the circumstances, the country of origin of the track shoe will be Italy. 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