The country of origin of telescoping extension poles

N357401 January 21, 2026 OT:RR:NC:N1:164 CATEGORY: Origin Miller Yang Jinmao (Tangshan) Import & Export Corp., Ltd. Houhu Industrial Park, Yutian County Tangshan City, Hebei Province 064100 China RE: The country of origin of telescoping extension poles Dear Miller Yang: In your letter dated December 30, 2025, you requested a country of origin ruling on telescoping extension poles. Product information was included with your request. The items under consideration are two types of telescoping extension poles which are designed to provide users with an adjustable means of extending their reach for painting and general maintenance applications. As you described, the products primarily consist of inner and outer tubes. During use, the outer tube is extended and retracted relative to the inner tube. This concerted action provides the user with a stable yet adjustable extension pole to reach greater distances. The fiberglass-aluminum twist lock extension pole model consists of a fiberglass outer tube, an aluminum inner tube, a plastic handle, various plastic locking parts, a rivet, a zinc thread tip, and a screw. In its retracted state, it measures 4.3 feet in length. When adjusted to its fully extended position, it measures 8 feet in length. Production of the fiberglass-aluminum extension pole begins in China where fiberglass undergoes forming into the outer tube by pultrusion. In addition, the zinc thread tip, the screw, and the plastic raw material are sourced from China. Manufacturing continues in Thailand where Thai-origin aluminum tube is cut to the length of the inner tube. Also in Thailand, the Chinese-origin plastic material is injection molded to form the plastic locking parts. The final assembly of all components is completed in Thailand prior to shipment to the United States. The aluminum-steel telescoping pole model consists of a steel outer tube, an aluminum middle tube, and an aluminum inner tube. Additionally, it includes several smaller components including a plastic grip, a plastic handle, plastic locking parts, metal extension parts, metal locking parts, and a zinc thread tip. In its retracted state, it measures 2.41 feet in length. When adjusted to its fully extended position, it measures 5 feet in length. Production of the aluminum-steel extension pole begins in China where Chinese-origin steel tube is cut and powder coated to form the outer tube. Additionally, the zinc thread tip, the metal extension and locking parts, and the plastic raw material are sourced from China. In Thailand, Thai-origin aluminum tube is cut to form the aluminum middle and inner tubes. After cutting, the aluminum inner tube also undergoes hole punching by a hole punching machine. Also in Thailand, the Chinese-origin plastic material is injection molded to form the plastic locking parts. Like the fiberglass-aluminum model, final assembly of all components is completed in Thailand where the finished product is 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). In both manufacturing scenarios, the extension poles consist of components from China and Thailand which are brought together in Thailand to form finished extension poles. Based on the description provided, the core function of the extension poles is to provide a user with an adjustable extension pole for a user to reach distances as desired. It is not until assembly processes in Thailand that the extension poles, in this functional context, exist. Prior to assembly in Thailand, the component poles are separate fixed-length poles which are incapable of extending beyond their own lengths. However, when they are assembled together with the smaller plastic and metal components, they gain the ability to extend and retract relative to one another, resulting in a singular, cohesive extension pole. During the assembly processes in Thailand, the components lose their individual identities and transform into an article with a new name, character, and use. Accordingly, the country of origin will be Thailand. 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 (C.F.R.), 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 C.F.R. 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 Taylor at paul.m.taylor@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division