The country of origin of a thread depth tire gauge

N361331May 27, 2026OT:RR:NC:N1:105
CATEGORY: OriginFangyi TianAutowin Group LimitedFlat/Rm 08, 15/F, Witty Commercial Building1A-1L Tung Choi StreetMongkok KowloonHong KongChinaRE: The country of origin of a thread depth tire gaugeDear Ms. Tian:In your letter dated
May 7, 2026
, you requested a country of origin ruling on a thread depth tire gauge.Descriptive literature was provided for our review.The item under consideration is described as a thread depth tire gauge (item number SP019), which isdesigned for the measurement of remaining vehicle tire tread depth. The gauge helps monitor tire wear,thereby enhancing driving safety, mitigating the risk of hydroplaning, and ensuring compliance with legal tiretread depth regulations. To operate the gauge, users should first clear the tire tread surface of any debris ormoisture. Subsequently, the measuring probe is inserted vertically into a tire tread groove until the base platerests flush against the tire surface. The tread depth value is then obtained by reading the scale on the gauge. Areading within the green zone signifies normal tire condition. The yellow zone serves as a warning, indicatingthat tire wear is nearing the replacement limit. A reading in the red zone necessitates immediate tirereplacement. The device measures 85mm in length, 11.2mm in width, and 26.7mm in height, with a weightof 9.5g. Its construction comprises an ABS base, a carbon steel measuring pin, a stainless-steel hexagonalcolumn, a steel pipe, and a carbon steel pen clip.The thread depth tire gauges are manufactured in Malaysia with components from both Malaysia and China.The Malaysian components include the plastic base, measuring pin, and hexagonal stainless-steel column.The stainless-steel pipe and carbon steel pen clip are sourced from China. The eight-step manufacturingprocess starts in Malaysia with the injection molding of the plastic base before measuring pin stamping andnickel plating. Step three and four both occur in China and include the steel tube cutting and pen clipstamping followed by chromium plating each component. Back in Malaysia, the ruler injection molding andprinting occurs before final assembly, testing and packaging.
When determining the country of origin, 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).Regarding the origin of the thread depth tire gauge, it is our opinion that the manufacturing and assemblyprocess performed in Malaysia transforms the individual components from China into a finished thread depthtire gauge. The components each have a change in name, character, and use. Therefore, in our opinion, thecountry of origin of the thread depth tire gauge is Malaysia, which is where the assembly process occurs, halfthe components are manufactured, and the Chinese components are transformed into a finished thread depthtire gauge.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 Jason Christie at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division