The country of origin of rubber transmission belts

N353013
September 11, 2025
OT:RR:NC:N5:137
CATEGORY: Origin Songzhou Jiang Fengmao (Thailand) Co. LTD. No.481, Group 2, Pananikhong Street,Nikhong Phatthana District Rayong Province, Thailand RE: The country of origin of rubber transmission belts Dear Mr. Jiang: In your letter dated August 28, 2025, you requested a country of origin ruling on rubber transmission belts Item 1 is a timing belt. It is a synchronous belt composed of a layer of rubber incorporating glass fiber cord with a layer of fabric on the teeth. The rubber is either hydrogenated nitrile butadiene rubber (HNBR) or chloroprene rubber (CR) of Thai origin; the glass fiber cord is of either German or Japanese origin; and the high elastic nylon fabric is of English or Japanese origin. The imported belt is ready for use and requires no further processing after importation. All manufacturing steps take place in Thailand. Compound rubber undergoes a calendaring process to adjust the thickness of the sheet and incorporate the wedge (cogged) surface. Once the appropriate thickness is obtained, the rubber sheet is fed onto a splicing machine. The product then undergoes the building process where the cord is incorporated into the rubber, and the fabric is applied to the teeth. The slab is placed into a vulcanizer to be cured at high temperature and pressure. After the slab is cooled it is placed on the grinding machine to create a smooth surface. The slab undergoes a cutting process to create pieces according to specifications. The belts are measured, inspected, and packed for shipment. Item 2 is a cogged belt. It is a synchronous belt composed of a layer of rubber incorporating polyester cord with a layer of fabric on the backside. The ethylene propylene diene monomer (EPDM) rubber is of Thai origin, the polyester cord is of German or Japanese origin, and the backside fabric is of English origin. The imported belt is ready for use and requires no further processing after importation. All manufacturing steps take place in Thailand. Compound rubber undergoes a calendaring process to adjust the thickness of the sheet and incorporate the wedge (cogged) surface. Once the appropriate thickness is obtained, the rubber sheet is fed onto a splicing machine. The product then undergoes the building process where the cord is incorporated into the rubber, and the fabric is applied to the backside. The slab is placed

into a vulcanizer to be cured at high temperature and pressure. After the slab is cooled it is placed on the grinding machine to create a smooth surface. The slab undergoes a cutting process to create pieces according to specifications. The belts are measured, inspected, and packed for shipment. Item 3 is a serpentine belt (grinding belt). It is a belt with a trapezoidal cross-section (V ribbed belt) incorporating between 3 and 20 ribs based on specifications. The belt is composed of a layer of smooth (backside) EPDM rubber, a layer of polyester or nylon cord and a layer of ribbed EPDM rubber. The EPDM rubber is of Thai origin; the polyester or nylon cord is of German or Japanese origin. The imported belt is ready for use and requires no further processing after importation. All manufacturing steps take place in Thailand. Compound rubber undergoes a calendaring process to adjust the thickness of the sheet. Once the appropriate thickness is obtained, the rubber sheet is fed onto a splicing machine. The product then undergoes the building process where the cord is wrapped between two layers of rubber. The slab is placed into a vulcanizer to be cured at high temperature and pressure. After the slab is cooled it is placed on the grinding machine to create a smooth surface. The slab undergoes a cutting process to create pieces according to specifications. The belts are measured, inspected, and packed for shipment. Item 4 is a serpentine belt (molded). It is a V-ribbed belt incorporating between 3 and 20 ribs based on specifications. The belt is composed of a layer of fabric (backside), a layer of polyester or nylon cord, a layer of EPDM rubber and a layer of fabric (rib-side). The fabric is of English or Japanese origin; the polyester or nylon cord is of German or Japanese origin; and the EPDM rubber is of Thai origin. The imported belt is ready for use and requires no further processing after importation. All manufacturing steps take place in Thailand. Compound rubber undergoes a calendaring process to adjust the thickness of the sheet. Once the appropriate thickness is obtained, the rubber sheet is fed onto a splicing machine. The product then undergoes the building process where the backside fabric is wrapped on a sleeve, the cord is wound onto the fabric, the rubber is wound over the cord. The final layer of fabric is placed into the mold followed by the slab. The product undergoes vulcanization at high temperature and pressure. After the slab is cooled it undergoes a cutting process to create pieces according to specifications. The belts are measured, inspected and packed for shipment. Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 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” within the meaning of the marking laws and regulations. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). The manufacturing steps, conducted in Thailand to produce the transmission belts, result in a substantial transformation. Therefore, the country of origin of the transmission belts is Thailand. 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 Christina Allen at [email protected].
Sincerely,
(for) Denise Faingar Acting Director National Commodity Specialist Division