The country of origin of vibratory rollers

N361263May 21, 2026OT:RR:NC:N1:103
CATEGORY: OriginTracy EvansFOCUS Business Solutions, Inc.6995 Monroe BoulevardTaylor, MI 48180RE: The country of origin of vibratory rollersDear Ms. Evans:In your letter dated
May 5, 2026
, you requested a country of origin ruling on behalf of your client, ThirdCoast Equipment Inc.The subject vibratory rollers are identified as steel drum soil and asphalt vibratory rollers, which includeDouble Drum Asphalt Rollers (models RA29 and RA45) and Single Drum Soil Rollers (models RS35, RS50,and RS70). The Double Drum Asphalt Rollers are described as articulating rollers with a vibratory drum andare designed for compacting and smoothing asphalt surfaces. The Single Drum Soil Rollers are described asarticulating rollers with a vibratory drum and rear pneumatic tires. They are used to compact soil during theconstruction of parking lots, roads, and warehouses. Both categories of vibratory rollers are manufacturedusing the same process.Final assembly occurs in Japan. A front drum assembly, manufactured in Japan and comprising a steel drumand vibratory mechanism, is mounted to a rear frame assembly. The rear frame assembly, produced in China,serves as the frame and chassis of the vibratory roller and contains the engine, hydraulic system, fuel tank, oiltank, drive system, canopy, and control system. These components are incorporated into a structural frame inChina, which is then shipped to Japan for final assembly.The final assembly process involves mounting the drum assembly to the rear frame assembly, attaching thedrive motor, connecting the hydraulic hoses, filling the hydraulic oil tank and purging air from the system,pressure testing the oil reservoir for leaks, and greasing all joints and fittings. Once assembly is complete,vibration, driving, and safety tests are performed.When determining the country of origin for purposes of applying current trade remedies under Section 301,Section 232, 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 asubstantial 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).In your submission, you argue that the country of origin of the finished vibratory rollers should be based onthe origin of the drum assembly. As described above, the vibratory rollers will be assembled by combiningtwo assemblies. While the Japanese drum assembly is an important component, the Chinese rear frameassembly contains numerous structural, mechanical, and electrical systems that are integral to the operationof the final machine. They include the chassis, control system, propulsion system, power drive systems, andother key components. This assembly accounts for a significant portion of both the value and the number ofcomponents in the finished machine. Thus, based on the totality of the circumstances, the country of origin ofthe Double Drum Asphalt Rollers (models RA29 and RA45) and Single Drum Soil Rollers (models RS35,RS50, and RS70), will be China.The 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 and Border ProtectionRegulations (19 C.F.R. 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, please contactNational Import Specialist Paul Huang at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division