Country of origin and marking of plastic and aluminum components from China to be assembled in the United States

N361065May 22, 2026OT:RR:NC:N5:116
CATEGORY: OriginMichael AnzalonePrecision Signs.com, Inc.243 Dixon Ave.Amityville, NY 11701RE: Cuntry of origin and marking of plastic and aluminum components from China to be assembled in otheUnited StatesDear Mr. Anzalone:In your letter dated
April 28, 2026
, you requested a country of origin ruling for the purposes of marking plastic and aluminum components from China for use in the assembly of non-illuminated signage products articles from China are described as an aluminum extrusionmanufactured in the United States (U.S.). Themade from Aluminum Alloy 6063 (Al-Mg-Si), an injection-molded mounting bracket body, andy, all used in theinjection-molded mounting bracket core, and an injection-molded sign frame boconstruction of complete signage assemblies.You explain that the plastic and aluminum components from China are designed to be used solely in thecomplete signage assembliesmanufacture of and will not be sold in their condition as imported. Specifically,the imported components from China are assembled with U.S.-made components to create custom signage Descriptive information and flow charts wereassemblies tailored to your customers' exact specifications.provided.You request the subject aluminum and plastic components be excepted from individual marking since theyare substantially transformed by machining and/or assembly operations performed by your company in theU.S. and that Precision Signs is the ultimate purchaser of these imported components.The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unlessexcepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in aconspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) willpermit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the countryof origin of the article.Part 134, Customs Regulations (19 CFR Part 134) implements the country of origin marking requirements and exceptions of 19 USC 1304.Section 134.1(d) defines the ultimate purchaser as generally the last person in the U.S. who will receive thearticle in the form in which it was imported.19 CFR 134.1(d)(1) states that if an imported article will be
used in manufacture, the manufacturer may be the ultimate purchaser if the manufacturer subjects theimported article to a process which results in a substantial transformation of the article.The case of U.S. v., 27 C.C.P.A. 267 (C.A.D. 98) (1940), provides that an article used in manufactureGibson-Thomsen Co., Inc.which results in an article having a name, character or use differing from that of the constituent article will beconsidered substantially transformed and that the manufacturer or processor will be considered the ultimatepurchaser of the constituent materials. Pursuant 19 CFR 134.35, in such circumstances, the imported article isexcepted from marking and only the outermost container is required to be marked. Based on the information provided, we find that Precision Signs is the ultimate purchaser of the subject plastic and aluminumcomponents. In accordance with 19 CFR 134.35, the aluminum extrusion made fromAluminum Alloy 6063 (Al-Mg-Si), an injection-molded mounting bracket body, an injection-molded areused by Precisionmounting bracket core, and an injection-molded sign frame body sourced from China Signs in the assembly of non-illuminated signage products manufactured in the U.S. and not sold separatelyin their condition as imported, are excepted from individual marking. Only the outermost containers of theimported articles must be marked with country of origin of China.Please be advised that aluminum extrusions may be subject to antidumping duties and/or countervailingduties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the Enforcementand Compliance office in the International Trade Administration of the Department of Commerce (ITA) andare separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP).General information regarding the ITA and AD/CVD can be found at . The ITA’s “Guide on How to File for anhttps://www.trade.gov/us-antidumping-and-countervailing-dutiesAntidumping/Countervailing Duty Scope Ruling Request” is available at . https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdfThe holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, contactNational Import Specialist Neil M Cohen at [email protected]
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division