The Country of Origin of 7 iron golf club heads finished in China

N357746 February 11, 2026 OT:RR:NC:N4:424 CATEGORY: Country of Origin Michael Toole Maersk Customs Service 180 Park Avenue Florham Park, NJ 07932 RE: The Country of Origin of 7 iron golf club heads finished in China Dear Mr. Toole: This is in response to your letter dated January 13, 2026, requesting a country of origin determination on behalf of your client, Cobra Golf Incorporated. A description of the manufacturing processes of 7 iron golf club heads was submitted for our review. The merchandise under consideration concerns three models of golf club heads imported by Cobra Golf Inc., which are identified as the following: Item Number Item Name HD0A01R7 HD IR 3DPT SV BK RH MNS 7 STD HD0B01R7 HD IR 3DPM SV BK RH MNS 7 STD HD0C01R7 HD IR 3DPX SV BK RH MNS 7 STD According to the information that you have provided in your letter, the manufacturing process for all three golf club heads occurs in Vietnam through a process called “3D Printing” with a CAD (Computer-Aided Design). The manufacturing process performed in Vietnam: Direct Metal Laser Sintering (3D Printing) Process 1. CAD File Preparation – Cobra Golf develops a 3D CAD model of the golf club iron head and send the design to the factory in Vietnam. The factory adjusts the model and adds processing stock and any supporting structure required for the 3D printing of the golf club iron head. The 3D CAD model is then converted to a Stereo Lithography (STL) file which “slices” the golf club iron head model’s geometry into thin layers. 2. 2. Machine Setup – The factory loads the Chinese origin stainless-steel metal powder, (316 SS/316L) into the 3D printing machine, and the chamber is filled with an inert gas (argon or nitrogen typically) to avoid oxidation. 3. Powder Layer Deposition – The 3D printing machine deposits and spreads a thin layer of the metal power across the build tray. 4. Laser Scanning and Melting – A high powered laser selectively melts the metal powder per the sliced geometry created from the STL file, which then solidifies. 5. Repetition – Steps 4 and 5 are repeated, thin layer by layer, until the AP golf club iron head is complete. 6. Cooling and Removal – The AP golf club iron head cools inside the 3D printing machine to prevent warping and reduce the amount of thermal stress. The golf club head is then removed by either a wire Electrical Discharge Machine (EDM) or band saw. 7. Post – Processing – any of the supporting structure used during the build that is not intended as part of the finished product is removed, typically via machining. The AP iron head consists of a body made of 316L stainless steel, along with two “caps” that are installed on the heel and toe of the AP Iron head’s sole to cover the pockets that accept two MIM tungsten pieces at 18g/cm3 density. There is also a MIM tungsten piece installed in the hosel bore at 9g/cm3 density. Subsequently, the raw AP golf club iron head and caps will be shipped from Vietnam to China for post 3D printed processing and finishing. The finishing operations performed in China: 1. The China finishing factory receives the AP head and caps from Vietnam and installs two tungsten pieces that it manufactures into the AP head’s heel and toe pockets. It covers the pockets with the two matching AP caps provided by the Vietnam factory. The China factory then welds the two caps to the AP head to secure the tungsten. 2. The head then goes through a machining process to add in the missing artwork and remove excess material. 3. The head undergoes a polishing process using various course belts to get close to the net/final shape. 4. The entire head is then coated with nickel-chrome plating. In between the nickel and chrome plated layers there are two areas of the head that are blasted with #120 ceramic beads or a #180 Aluminum 203 blast media. 5. The final polishing, after chrome plating is completed, is done with a #180 sponge wheel for final head finish. 6. Matte black paint is applied in the artwork on the head and laser etched. 7. Then the Hosel tungsten is glued in. The finished 7 Iron Golf Club Head dimensions are approximately 4.4 in x 3.5 in x 1 in. When determining the country of origin, the substantial transformation analysis is applicable. 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). In order to determine whether a substantial transformation occurs when components of various origins are assembled into completed products, all factors such as the components used to create the product and manufacturing processes that these components undergo are considered in order to determine whether a product with a new name, character and use has been produced. No one factor is decisive, and assembly operations that are minimal will generally not result in a substantial transformation. This office reviewed the submitted production process for the 7 iron golf club heads. The golf heads are fully formed in Vietnam via the 3D printing processes described above. The finishing operations performed in China give the aesthetics to the formed golf heads but would not substantially change them. We agree with your suggestion that the country of origin for these golf club heads is 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 Irene Tsiavos at Irene.Tsiavos@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division