The tariff classification, country of origin, and marking of golf club heads

N362267 July 10, 2026 CLA-2-95:OT:RR:NC:N4:462 CATEGORY: Classification TARIFF NO.: 9506.39.0060 Laurie Bichell Maersk Customs Services USA Inc. 1501 South Clinton Street, Suite 210 Baltimore, MD 21224 RE: The tariff classification, country of origin, and marking of golf club heads Dear Ms. Bichell: In your letter dated June 12, 2026, you requested a classification, country of origin, and marking ruling on behalf of your client, Cobra Puma Golf. A description of the manufacturing processes of three golf club heads was submitted for our review. The merchandise under consideration concerns three models of golf club heads, identified as Golf Club Head, 52° (item number HD0T01R52V), Golf Club Head, 56° (item number HD0T01R56V), and Golf Club Head, 60° (item number HD0T01R60V). Each head measures approximately 5” x 4” x 1.75” and weighs approximately 299 grams. The material composition is AISI 1025 carbon steel. According to the information that you have provided in your letter, manufacturing operations for the golf club heads occur in Taiwan. Steel billets sourced from China are cut and heated, a four-stage forging process shapes the head, flash trimming removes excess material, and progressive die refinement produces a near-net shape golf club head. The heads are then sent to Vietnam. In Vietnam, post-processing machining (hosel boring and detailing), polishing, abrasive finishing, surface blasting, nickel-chrome plating, and cosmetic finishing (paint fill and laser etching) are performed. CLASSIFICATION You suggest classification for the golf club heads under subheading 9506.39.00, Harmonized Tariff Schedule of the United States (HTSUS). We agree. The applicable subheading for the three golf club heads will be 9506.39.0060, HTSUS, which provides for, "Articles and equipment for general physical exercise, gymnastics, athletics, other sports or outdoor games… Golf clubs and other golf equipment; parts and accessories thereof: Other, Parts of golf clubs." The rate of duty will be 4.9 percent ad valorem. ORIGIN AND MARKING 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). 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. This office reviewed the submitted production process for the three golf club heads. It is our opinion that the manufacturing operations performed in Taiwan provide the essence of these articles. The above-mentioned forging from the steel billets to the final shape of the golf heads takes place in Taiwan. The finishing processes performed in Vietnam give the aesthetics to the forged golf club heads, which originated in Taiwan, but would not substantially change them. Therefore, based on the facts presented in this case, the country of origin for all three golf club heads for marking and trade remedy purposes is Taiwan. Further, we advise that provided the golf club heads are legibly, indelibly, and permanently marked “Made in Taiwan,” such marking would satisfy the requirements of 19 U.S.C. § 1304 and 19 CFR Part 134. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. 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 Sandra Walia at sandra.s.walia@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division