The country of origin of a tire spoon

N362467 July 2, 2026 OT:RR:NC:N1:118 CATEGORY: Origin Ling Tang Zhejiang Feiling Tools Co., Ltd. No.18 Huangliyang Industrial Estate Jiande 311600 China RE: The country of origin of a tire spoon Dear Mr. Tang: In your submission dated June 22, 2026, you requested a country of origin ruling for purposes of Section 301 duties, other tariffs and marking. Pictures and descriptions of the manufacturing processes were included in your submission. The item under consideration is identified as a tire spoon, SKU 85533. It is a hand-operated tool used for mounting and demounting pneumatic tires from vehicle wheel rims. It consists of a steel shaft with a formed spoon end attached to a plastic handle. The tool operates by using the spoon-shaped steel end to engage and lever the tire bead over the rim. Force applied by the user is transmitted through the steel shaft to the working end, enabling the tire to be lifted, guided, or removed. The manufacturing process for the tire spoon begins in Thailand, where Chinese-origin steel coil is straightened to ensure uniform flatness and is cut to the required lengths of the shaft. The cut steel piece undergoes precision machining operations to form the functional geometry of the tool shaft. One end of the shaft is then pressed and formed into the spoon-shaped working end. The shaft is subsequently bent to specified angles to create the geometry and leverage required for tire mounting and demounting and additional forming operations are performed to create the final shape, contours, and dimensions. It is then polished to remove burrs and improve the surface finish, before it is sent to China. In China, the shaft is heat treated, electroplated, and assembled with a Chinese-origin injection-molded plastic handle. 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 tire spoon, it is our view that steel coil is substantially transformed in Thailand into the fully formed shaft section of the tool. This consists of its final functional shape with the spoon-shaped working end. It is this shaft that contributes to the main functionality of the finished tool. Although not ready for immediate use, the shaft that arrives in China has a pre-determined use and is in a dedicated physical form of a tire spoon. It is therefore our opinion that the country of origin of the finished tire spoon, SKU 85533, is Thailand. 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 Anthony Grossi at anthony.e.grossi@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division