The country of origin of a tape measure

N358597 February 19, 2026 OT:RR:NC:N1:105 CATEGORY: Origin Fay Jin GreatStar Industrial USA, LLC. 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The country of origin of a tape measure Dear Mr. Jin: In your letter dated February 6, 2026, you requested a country of origin ruling on a tape measure. Descriptive literature was provided for our review. The item under consideration is described as a tape measure, which is a versatile tool utilized by tradespeople, inspectors, contractors, homeowners, and various consumers for accurate and rapid distance measurement. Its compact, retractable design facilitates the measurement of both short and extensive lengths, while its portability allows for easy storage in a pocket or toolkit. The instrument features a 25-foot long, flexible yellow steel ruler tape marked with linear measurements in feet, inches, and fractions down to 1/32 inch. This flexible steel strip is capable of conforming to curves and corners. Internally, the tape coils around a plastic wheel housed within a plastic casing, driven by a metal spring mechanism that enables automatic retraction. Additional functionalities include a sliding button for locking the tape in position and a floating hook on the end for secure attachment during measurements. The tape measure is constructed of Chinese and Cambodian raw materials. The Chinese materials include the tape casting, shell encapsulation, push button, push knob with rubber coating, roller core cylinder, role core bottom, roll core cap, ruler spring, ruler hook, ruler pad, spacer plate, rivet, screws, and belt buckle. The Cambodian material includes the blade with printed measurements. The manufacturing process for the tape measure begins in China, where steel strips are precisely cut to the required width. These narrow strips then undergo heat treatment and receive a yellow base coating. Following these initial steps, the coated strips are shipped to Cambodia for the application of scale and numerical markings via ink printing. Once printed, the measuring tape blades are returned to China for further processing. This includes the application of a clear varnish coating, precision cutting to specified lengths, and final assembly with other components sourced from China, such as the tape casing, push button, and hook, to produce a complete tape measure. When determining the country of origin, 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). Regarding the origin of the tape measure, while the application of numerical markings on the metal tape is an essential step in its production as a measuring device, all of the remaining components are of Chinese origin. The metal tape, pre-cut to the specified dimensions and already bearing paint, was exported to Cambodia solely for the application of these numerical markings. The process of adding these markings constitutes a minor cost, requires minimal time, and involves simple manufacturing processes, thus it does not effect a substantial transformation of the tape measure, imparting a new name, character, or use distinct from its state upon departure from China. Furthermore, upon its return to China, the marked tape is integrated into the final assembly with components exclusively designed for tape measure functionality. Consequently, it is our determination that the country of origin of the tape measure is China, reflecting the origin of the predominant components and the location of the principal assembly operations. 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division