The country of origin of a Hand-Held Spreader

N359220 March 24, 2026 OT:RR:NC:N4:422 CATEGORY: Origin Ms. Jessica Islas-Parker A. N. Deringer 173 West Service Rd. Champlain, NY 12919 RE: The country of origin of a Hand-Held Spreader Dear Ms. Islas-Parker: In your letter dated February 24, 2026, you requested a country of origin ruling on behalf of your client, Meridian International Co., Ltd. Pictures of the merchandise in different stages of manufacture were included with your submission, along with manufacturing flow charts. The item under consideration is identified as a Hand-Held Spreader. The hand-held spreader is a a small, manually driven centrifugal spreading device that is used to disperse material such as seeds and fertilizers over small flower beds, green belt edges, and courtyard corners. The user holds the device and directly drives the spreading impeller/disc inside the hopper. The opening of the hopper gate is controlled via the flow adjustment dial on the side of the body, regulating the material's falling speed. The material falls from the bottom of the hopper onto the rotating impeller. The rotating impeller uses centrifugal force to throw the material outward. Some models are equipped with a deflector plate, which can control the spreading direction, directing the material to one side or forming a specific fan-shaped coverage area. You have stated that the manufacturing process Hand-Held Spreader begins in Cambodia, where raw plastic materials are used for injection molding the following subcomponents: hopper, upper base, and lower base. In China, raw plastic materials are used for injection molding of the subsequent subcomponents: long helical gear, shaft gear, side gear, arm support, trigger, gear switch, agitator, spread plate, grip (left), grip (right), level 1, trigger plate, level 2, and handle lock pin. Next, the Cambodian subcomponents (i.e., the hopper, upper base, and lower base) are shipped to China and manually assembled with the Chinese subcomponents. Finally, the finished Hand-Held Spreader is packaged for retail sale before shipment 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” 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 in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Regarding the Hand-Held Spreader, it is our view that the Cambodian subcomponents (i.e., the hopper, upper base, and lower base) perform the essential function of the finished spreader. The hopper holds the material being spread, the upper base protects the internal gear transmission, and the lower base supports the internal gear set, agitator, and operating mechanisms to ensure overall structural stability. It is our opinion that these subcomponents do not lose their identity or character when assembled with the Chinese subcomponents. Therefore, the country of origin of the Hand-Held Spreader is Cambodia. 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 Dana L. Giammanco at dana.l.giammanco@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division