The Country of Origin of titanium golf club driver heads finished in China

N308962 February 12, 2020 OT: RR: NC: N4:424 CATEGORY: Country of Origin Ms. Jane Taeger Vandergrift Forwarding Company, Inc. 20 South Charles Street Baltimore, MD 21201 RE: The Country of Origin of titanium golf club driver heads finished in China Dear Ms. Taeger: This is in response to your letter dated January 14, 2020, requesting a country of origin determination on behalf of your client, Cobra Golf Incorporated, of Carlsbad, California. A description of the manufacturing processes of golf club driver heads was submitted for our review. The merchandise under consideration concerns two models of golf club driver heads imported by Cobra Golf Inc., which are identified as the “SZ Driver” and the “F-MAX” driver heads. According to the information that you have provided in your letter, the manufacturing process for both golf club driver heads occurs in Taiwan. You state that the titanium driver golf heads are formed through a series of casting processes in Taiwan using raw titanium sourced from China. The production process for the driver heads includes treating, melting and casting raw titanium using wax injection molds. Specifically, the process begins by injecting wax into a tooling or mold to form the shape of the finished golf head. The waxes, carrying the construction and characteristic details of a golf head, are assembled and layered together to create thick, heat-resistant hard shell clusters. The titanium material is melted in a high-temperature furnace and is then cast into the de-waxed, pre-heated shell clusters. After the casting is complete, the shell clusters undergo a de-shelling process and are broken into individually casted golf heads. Each casted titanium golf head is further sandblasted and polished into the final size and shape of the corresponding golf head model. The titanium driver golf heads are then inspected, packed and shipped to China for the final cosmetic finishing operations. According to your request, the finishing operations in China include face or crown welding, hosel machining, masking and painting or PVD coating, and decal application resulting in the cosmetically finished golf heads. The finished golf heads are then inspected, packed and exported to a final destination. With regard to your request for the appropriate country of origin of the aforementioned golf driver heads, 19 C.F.R. § 134.1(b) provides in pertinent part as follows: Country of origin means 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.” A substantial transformation occurs when articles lose their identity and become articles having a new name, character, or use. In order to determine whether a substantial transformation occurs when components of various origins are assembled into completed products, all factors such as the components used to create the product and manufacturing processes that these components undergo are considered in order to determine whether a product with a new name, character and use has been produced. No one factor is decisive, and assembly operations that are minimal will generally not result in a substantial transformation. In this instance, it is this office’s opinion that the manufacturing operations of the “SZ Driver” and the “F-MAX” titanium driver heads in Taiwan provide the essence of these articles. The above-mentioned titanium casting processes from the raw titanium material to the final shape of the golf head takes place in Taiwan. The finishing processes performed in China give the aesthetics to the casted golf heads, which originated from Taiwan. In our view, these items are not substantially changed by the welding, machining or the cosmetic finishing processes performed in China. Therefore, based on the facts presented in this case, the country of origin of the “SZ Driver” and the “F-MAX” driver heads is Taiwan. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 177). 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 19 CFR 177.9(b)(1). In the event that the facts or merchandise are modified in any way, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and you should resubmit for a new ruling in accordance with 19 CFR 177.2. 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 Roseanne Murphy at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division