The country of origin of low profile floor jacks

N354790
October 28, 2025
OT:RR:NC:N1:103
CATEGORY: Origin Gloria Gao JACKUP International Company Limited Room 1703, Yishi Mansion, No.95 Zhongshan Bei Road Nanjing City, Jiangsu Prov. 210009 China RE: The country of origin of low profile floor jacks Dear Ms. Gao: In your letter dated October 8, 2025, you requested a country of origin ruling. The subject low profile hydraulic floor jacks are used to lift heavy loads through short distances and are suitable for use during automotive service or general machine maintenance. The jacks will be imported under three model numbers: a 1.5-ton low profile aluminum floor jack (model number JA-SFJ-195T); a 2.5-ton low profile aluminum floor jack (model number JA-HGJ-255T); and a 2-ton big wheel off-road jack (JA-ORJ-277T). The three models are identical in function but will have different lifting capacities and maximum lifting heights. The big wheel off-road jack will also have more durable wheels and include a saddle extension. All three models will be produced using the same manufacturing scenario, with final assembly occurring in Thailand using components sourced from China and Thailand. The Chinese components include a lifting arm assembly, aluminum side plates, a cover plate, a handle, a handle bracket, a saddle, a pump core, front wheels, rear casters, and more. The only Thai component is a casting that will serve as the base for the pump unit. The main components of the hydraulic jacks are identified as the lifting arm assembly, the frame assembly, and the hydraulic unit. According to your submission, the operational steps that occur in Thailand begin with inspecting, cleaning, and drying the components for the hydraulic unit. Once the components are cleaned, they are assembled using operational steps described as combining the base, a pump housing, a cylinder body, a piston rod, a top cap, springs, washers, and other hardware into a hydraulic unit. Separately, the Chinese lifting arm assembly is attached to the frame assembly, which is formed by welding the side plates and other smaller metal shapes (e.g., brackets, rods, etc.) together.

The final assembly process is described as assembling the hydraulic unit to the frame assembly, then incorporating the rear caster assembly, handle bracket, saddle, etc., and securing everything together using fasteners. The hydraulic jack is then tested, inspected, and packaged for export. 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). CBP has held that whether an assembly process is sufficiently complex to rise to the level of a substantial transformation is determined upon consideration of all the operations that occur within that country, including any subassembly processes that take place in that country. Based on your description of the manufacturing operations, we note that nearly all of the components are sourced from China as finished or semi-finished components, requiring only shot blasting and powder coating prior to assembly. The only component that is produced in Thailand is the base of the pump. Thus, based on the totality of the circumstances, the country of origin of the low-profile aluminum floor jacks (model numbers JA-SFJ-195T and JA-HGJ-255T) and the big wheel off-road jack (model number JA-ORJ-277T), will be China. 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division