The country of origin of a telehandler

N352101
August 27, 2025
OT:RR:NC:N1:103
CATEGORY: Origin Kensie Sugama Trade Pacific PLLC 700 Pennsylvania Ave. SE, Suite 500 Washington, DC 20003 RE: The country of origin of a telehandler Dear Ms. Sugama: In your letter dated August 6, 2025, you requested a country of origin ruling on behalf of your client, Putzmeister Makine San. Ve Tic. A.S. The merchandise under consideration is identified as a telehandler, model number STH1056A, which is a self-propelled lifting and handling machine with a long telescoping boom. The boom can be equipped with a variety of attachments, allowing the telehandler to lift, carry, and position heavy materials. This model has a maximum lifting height of 17 meters, a maximum forward reach of 13 meters, and weighs 15,100 kilograms. It is diesel-powered and has a maximum speed of 20 miles per hour. The subject telehandler is manufactured in Turkey using subassemblies and parts sourced from China, Germany, Hungary, India, Italy, Japan, Mexico, South Korea, Turkey, and the United Kingdom. The foreign subassemblies include a German engine, a Hungarian transmission, a Chinese fuel tank, a Japanese hydraulic drive system, and Italian axle assemblies (front and rear). These components are sent to Turkey for final assembly. The main subassemblies are identified as the frame assembly, boom assembly, and the cab assembly. The frame assembly and boom assembly are manufactured in Turkey from metal sheets, metal angles, steel plates, round steel bars, rectangular tubing, and other steel tubing. These metal forms are then manufactured into elements such as mounting plates, reinforcement plates, brackets, supports, connecting blocks, and more. The elements are next combined and welded into larger subassemblies that are subsequently assembled to form the frame assembly or boom assembly. The cab assembly is sourced from China as a finished subassembly. Final assembly begins with installing the axle assemblies to the frame assembly and mounting the wheels and tires. Next, workers install and connect various valve assemblies that will operate the telescoping sections of the boom, steering systems, and outriggers. At the next station, the outriggers are added, various electrical

wiring harnesses are connected, the hydraulic tank is installed, and the counterweight is bolted in place. Afterwards, workers pre-assemble the engine and transmission before mounting it in the frame, then install its accompanying drive fuel system, electrical system, radiator, and intake and exhaust systems. At this point, the frame is ready for the cab assembly and boom assembly, which are mounted to the frame then connected to their corresponding hydraulic and electrical systems. Lastly, the telehandler is tested, painted, and inspected. 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). Based upon your description of the manufacturing operations, the nature of the processing performed in Turkey is not simple. In addition to the final assembly occurring in Turkey, two of the major structural subassemblies (i.e., the frame assembly and the boom assembly) are manufactured from common metal forms (e.g., metal sheets, plates, and tubing) and transformed into integral subassemblies in Turkey. The combined operations result in the individual parts losing their separate identities to become a new article. Thus, based on the totality of the circumstances, the country of origin of the telehandler, model number STH1056A, will be Turkey. The merchandise in question may be subject to antidumping duties and countervailing duties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). You can contact them at https://trade.gov/enforcement/ (click on “Contact Us”). For your information, you can view a list of current AD/CVD cases at the United States International Trade Commission website at https://www.usitc.gov/trade_remedy/documents/orders.xls, and you can search AD/CVD deposit and liquidation messages using CBP’s AD/CVD Search tool at https://aceservices.cbp.dhs.gov/adcvdweb. 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 Paul Huang at [email protected].
Sincerely,
(for) James Forkan Acting Director National Commodity Specialist Division