The country of origin of ratchet tie downs

N352594
August 29, 2025
OT:RR:NC:N1:104
CATEGORY: Origin Bo Shao Wolit (Thailand) Co., Ltd. 178 Moo 1, Khlong Tamru Mueang Chonburi, Chonburi 20000 Thailand RE: The country of origin of ratchet tie downs Dear Bo Shao: In your letter dated August 19, 2025, you requested a country of origin ruling. The products in question are five styles of ratchet tie downs, each consisting of a gear and pawl ratchet buckle mechanism with a lever handle for tensioning, woven polyester webbing straps, and two metal hooks (S-hooks or double J-hooks) attached to the ends of the webbing strap. The ratchet tie downs are used to secure cargo and loads during transportation. The items will be produced in two countries, China and Thailand. Your submission included a manufacturing flowchart, a description of the processing, a Bill of Materials, and product specifications. The five ratchet tie downs are functionally the same with varying strap widths (between 1-2 inches) and different working load limits (300, 500, 1,000, 1,666, and 3,333 lbs.). In Thailand, spools of Chinese-sourced polyester yarn are woven into tie-down webbing, then dyed, cut, and inspected. Next, in Thailand, steel plates of Chinese origin are stamped and pressed into ratchet gears, handles, and frames, followed by zinc plating and powder coating. The webbing, ratchet buckle, and hooks are assembled in Thailand using industrial sewing machines and riveting processes. Finally, the ratchet tie downs undergo load-capacity testing, final inspection, and packaging in Thailand, with the outer packaging marked with the labels containing the words “Made in Thailand.” The “country of origin” is defined in Section 134.1(b) of the U.S. Customs and Border Protection (CBP) Regulations (19 CFR 134(b)) 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 to render such other country the ‘country of origin’ within the meaning of this part.” The substantial transformation test is also used to determine the country of origin for the purposes of Section 301 measures and other duties. See, e.g., Headquarters Ruling Letter (HQ) 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). CBP has determined in similar country of origin scenarios that the essential character of like ratchet tie-downs is imparted by the webbing straps, as purchasers are buying the tie down straps to secure their cargo. See HQ H305503, dated Feb. 20, 2020, and New York Ruling Letters N343501, dated Nov. 22, 2024, and N316901, dated Feb. 4, 2021. In this case, the straps are produced in Vietnam from Chinese polyester yarn and maintain their name, character, and use as tie down straps after simple assembly in Thailand with the Chinese origin ratchet components. Accordingly, the country of origin of the complete ratchet tie downs will be Thailand. You did not specifically request a marking ruling. In any case, you did not provide a sample image of a proposed country of origin marking label, its font size, the type of label, or its proximity to other words on the packaging, which may be needed to make a marking determination. Note that country of origin markings must comply with the Customs laws and regulations, 19 U.S.C. 1304 and 19 CFR 134. See also 19 U.S.C. 1304. Any exception to the marking requirements for outermost container marking must comply with 19 CFR 134.22 and 134.32. 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 the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. If 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 Arthur Purcell at [email protected].
Sincerely,
(for) Denise Faingar Acting Director National Commodity Specialist Division