The country of origin of tire repair plugs

N361884 June 18, 2026 OT:RR:NC:N5:137 CATEGORY: Origin Fangyi Tian Autowin Group Limited Flat/Rm 08, 15/F, Witty Commercial Building, 1A-1L Tung Choi Street, Mongkok, Kowloon Hong Kong China RE: The country of origin of tire repair plugs Dear Ms. Tian: In your letter dated May 29, 2026, you requested a country of origin ruling on tire repair plugs Item number SP001, SKU number 1687681, Tire Repair Plugs, are composed of polyester yarn that has been completely coated or embedded within a mixture composed primarily of butyl rubber. The product is a tubeless tire repair product. Butyl rubber, polyester yarn and a petroleum hydrocarbon resin are sourced in Malaysia. A vulcanizing agent and an accelerator are sourced in China. In Malaysia, the butyl rubber, petroleum hydrocarbon resin, vulcanizing agent and accelerator are weighed out according to a precise formula. They are added to a batching tank, heated and agitated to soften the rubber. They are then transferred to a mixer for complete blending. The polyester yarn is unwound from the reel and dipped into the rubber mixture to fully coat the yarn. The coated yarn enters a curing tunnel to be dried and cured at a set temperature. After drying, the rubber-coated yarn is rewound into rolls for subsequent processing. Multiple rubber-coated yarns are then fed into the laminating equipment where they are pressed into a flat composite slab. The laminated slab is slit into continuous rubber strips of specified widths. The slit rubber strips are stacked and loaded into a high-temperature test chamber. They are preheated to a set temperature and then vulcanized at the set temperature and time to form a stable three-dimensional cross-linked structure. They undergo product testing and are packaged for exportation to the United States. 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. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). The manufacturing processes performed in Malaysia results in a substantial transformation. Therefore, the country of origin, for marking purposes is Malaysia. 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 Christina Allen at julie.c.allen@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division