The country of origin determination of a transport bolt
Issued November 20, 2018 by U.S. Customs and Border Protection.
Tariff classification
Product description
The country of origin determination of a transport bolt
CBP rationale
substantial transformation in order to render such other country the “country of origin”. Based on the information submitted, this office is of the opinion that in this instance the assembly operation performed in China does not substantially transform the Taiwanese originating component into a Chinese product. The assembly in China of additional individual components to produce the finished transport bolt does not create a new and different article of commerce with a distinct character and use that is not inherent in the steel bolt that is imported into China from Taiwan.
Full text
N301395 November 20, 2018 MAR-2 OT:RR:NC:N1:121 CATEGORY: Country of Origin Ms. Raissa Quick Shamrock International 1475 E. Industrial Drive Itasca, IL 60143 RE: The country of origin determination of a transport bolt Dear Ms. Quick: This is in response to your letter dated October 25, 2018, requesting a country of origin determination for a transport bolt. This office reviewed the technical drawings you submitted. The article under consideration is identified as a transport bolt, part number SPW11041011-199. The transport bolt consists of a steel bolt, steel washer, plastic spacer and a bushing. It is used to secure the tub of a washing machine to prevent it from moving during transport. You state that the steel bolt is made in Taiwan and then shipped to China to be assembled with the steel washer, plastic spacer and the bushing, all of which are made in China. Section 134.1(b), Customs Regulations (19 C.F.R. § 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”. Based on the information submitted, this office is of the opinion that in this instance the assembly operation performed in China does not substantially transform the Taiwanese originating component into a Chinese product. The assembly in China of additional individual components to produce the finished transport bolt does not create a new and different article of commerce with a distinct character and use that is not inherent in the steel bolt that is imported into China from Taiwan. Therefore, the country of origin for the transport bolt, part number SPW11041011-199, will be Taiwan. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 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, contact National Import Specialist Jennifer Jameson at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division
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