The country of origin of rifle stocks

N350985
July 16, 2025
OT:RR:NC:N1:164
CATEGORY: Origin Spencer Gottlieb HUSH Holsters LLP 915 Broadway St. Vancouver, WA 98660 RE: The country of origin of rifle stocks Dear Mr. Gottlieb: In your letter dated July 7, 2025, you requested a country of origin ruling on rifle stocks. Technical information was submitted with your request. The items under consideration are described as rifle stocks for use with SKS type rifles. The subject rifle stocks are mainly comprised of a three dimensionally (3D) printed polymer stock, a metal folding mechanism assembly, and a pistol grip. You assert that the 3D printed polymer stock is the main component which interfaces with the rifle’s firearm components. In total, there are 18 discrete components sourced from Canada, the U.S., and China. In addition, you state that all assembly takes place exclusively in Canada. The breakdown of components is as follows: 1 - 3D printed polymer stock (Canada) 3 - Compression springs (China) 4 - Stainless steel components (China) 1 - Machined steel part (China) 1 - Welded subassembly (China) 7 - Fasteners and hardware elements (Canada) 1 - Pistol grip (U.S.) The production process begins when Canadian or U.S.-sourced polymer is prepared for 3D printing through a drying process. After the design programs are loaded onto the 3D printers, the printing process occurs. After several hours, the finished stocks are removed from the printers and undergo processing which includes support removal, surface inspection, bonding with adhesive, curing, and final inspection. Assembly of the 3D printed rifle stock with other components begins with inserting a post into a hole on the polymer stock, applying adhesive to the knob screw, and screwing it in place. Then, the pivoting bar is inserted into the pivot housing using washers and an alignment jig, so the pin is installed flush. At that point, compression springs are installed into the rear section of the rear grip. After that, a toggle button is placed

into the rear grip, firmly onto the springs. Next, the pivot housing and rear arm are joined using stainless steel fasteners and adhesive to the correct torque. A spring is inserted into the release button, and both are placed into the pivot housing. Following that, the release button is secured flush in place using a roll pin and press. The completed metal assembly is inserted into the polymer stock interface, aligned with jigs, and secured to correct torque using a locking washer screw and adhesive. Finally, the U.S. origin pistol grip is installed to the underside of the polymer stock and checked for fit. After this final assembly step, the rifle stocks are laser-engraved with required logos and serial number and undergo full functional inspection and packaging. 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). In this case, the main component of the subject rifle stocks is the 3D printed polymer stock which is formed in Canada. As you described, it is the component that provides the “chassis” for the rifle’s firearm components to sit in. After reviewing the submitted information and your website, it is clear that the 3D printed polymer stock is designed and manufactured with a predetermined physical form dedicated for end use as a rifle stock. After assembly in Canada with components from China and the U.S., the 3D printed polymer stock is not substantially transformed. No article emerges with a new, name, character, and use than which existed prior to the assembly in Canada. Accordingly, the country of origin of the rifle stocks is Canada. 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 (C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
(for) James Forkan Acting Director National Commodity Specialist Division