The country of origin of tire gauges

N361416May 29, 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 tire gaugesDear Ms. Tian:In your letter dated
May 11, 2026
, you requested a country of origin ruling on tire gauges. Descriptiveliterature was provided for our review.The items under consideration are described as tire gauges (model numbers SP013, SP014, and SP002),which are designed to measure tire air pressure. These devices function mechanically, relying on apressure-actuated piston and a graduated scale display without the need for batteries or electroniccomponents. Model SP013, measuring 158mm by 15.5mm by 30mm and weighing 43.8g, is constructedfrom a zinc alloy head, stainless steel tube, a nitrile butadiene rubber (NBR) gasket, 65Mn spring, ABS scale,and polypropylene (PP) valve cap. Similarly, model SP014, with dimensions of 149mm by 13.5mm by 18mmand a weight of 26.4g, shares the same material composition: a zinc alloy head, stainless steel tube, NBRgasket, 65Mn spring, ABS scale, and PP valve cap. In contrast, model SP002, which measures 148mm by14.4mm by 19.5mm and weighs 15.8g, features an ABS plastic head, stainless steel tube, NBR gasket, 65Mnspring, and an ABS scale.The tire gauges are manufactured in Malaysia, with components sourced from both Malaysia and China. Forthe SP002 model, the plastic head, rubber gasket, and scale are of Malaysian origin, while the stainless-steeltube, spring, and raw rubber and plastic components are sourced from China. The SP014 and SP013 modelsfeature a zinc alloy head, rubber gasket, and scale manufactured in Malaysia, with their stainless-steel tube,spring, and raw plastic and rubber components originating from China.The manufacturing processes for all three tire gauges are substantially similar. The SP002 model begins withthe injection molding and trimming of the plastic head, followed by iron pipe cutting, processing, and chromeplating. Subsequently, the spring undergoes heat treatment and coiling, leading to scale injection molding,scale pad printing, assembly, testing, and packaging. For the SP014 and SP013 models, the process starts
with die casting and chroming the zinc alloy head. This is followed by iron pipe cutting and processing,electroplating, vulcanization of the rubber, and spring heat treatment and coiling. The final processing steps,including scale pad printing, assembly, testing, and packaging, are identical for all three gauge models.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 tire gauges, it is our opinion that the manufacturing and assembly processperformed in Malaysia transforms the individual components from China into finished tire gauges. Thestainless-steel tube, spring, and raw plastic and rubber each have a change in name, character, and use.Consequently, we conclude that the country of origin of the tire gauges (model numbers SP013, SP014, andSP002) is Malaysia, which is where the assembly process occurs, most of the components are manufactured,and the Chinese components are transformed into finished tire gauges.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