The country of origin of a high-pressure dial tire gauge

N361491June 2, 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 high-pressure dial tire gaugeDear Ms. Tian:In your letter dated
May 12, 2026
, you requested a country of origin ruling on a high-pressure dial tire gauge.Descriptive literature was provided for our review.The item under consideration is described as a high-pressure dial tire gauge (model number SP022), which isa precision analog tire pressure measuring tool. To use the tool, you first remove the tire’s valve cap andpress the gauge’s specialized swivel angle chuck firmly down onto the valve stem to form an airtight seal.This physical contact depresses the core of the tire valve, allowing pressurized air to escape from the tiredirectly into the gauge’s internal mechanism. The force of this incoming air mechanically flexes the internalsolid elements, which translates the linear structural movement through a geared precision movement toswing the physical needle across the calibrated 2-inch dual-unit dial face. Since the SP022 features a built-inpressure retention mechanism, the needle locks at the peak measurement even after it is pulled away from thetire, allowing the user to easily read the final value. The device, measuring 158mm by 15.5mm by 30mm andweighing 43.8g, is constructed from a zinc alloy head, stainless steel tube, a nitril butadiene rubber (NBR)gasket, and a 65Mn spring.The tire gauge is manufactured in Malaysia, with components sourced from both Malaysia and China. The airinlet with relief button, cover shell, bottom shell, brass connector, plastic sleeve, and rubber are of Malaysianorigin, while the movement and raw rubber and plastic components are sourced from China.The manufacturing process, conducted in Malaysia, begins with the CNC machining of aluminum and brassheads. This is followed by the anodizing and assembly of the aluminum head. Subsequently, the protectivesleeve undergoes injection molding, and the housing is stamped and electrophoretically coated. The processthen involves procuring the movement, pointers, and lenses, preceding the welding and assembly of themovement’s copper head. Following this, the pointer and meter cover are installed, and screws are fastened to
secure the upper and lower covers. Finally, the protective sleeve is fitted, the aluminum head and meter bodyare assembled, and the completed device is tested and packaged.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 high-pressure dial tire gauge, it is our opinion that the manufacturing andassembly process performed in Malaysia transforms the individual components from China into a finishedhigh pressure dial tire gauge. The movement and raw rubber and plastic components each have a change inname, character, and use. Therefore, in our opinion, the country of origin of the high-pressure dial tire gauge(model number SP022) is Malaysia, which is where the assembly process occurs, most of the components aremanufactured, and the Chinese components are transformed into a finished high pressure dial tire 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