The country of origin of a tire iron

N361976
June 23, 2026
OT:RR:NC:N1:118
CATEGORY: Origin Fangyi Tian Autowin Group Limited Flat/Rm 08, 15/F Witty Commercial Building 1A-1L Tung Choi Street Mongkok, Kowloon, Hong Kong China RE: The country of origin of a tire iron Dear Ms. Tian: In your letter dated June 2, 2026, you requested a country of origin determination for marking purposes under Section 304 of the Tariff Act of 1930, as amended (19 U.S.C 1304). Item SP004 is identified as a tire iron. The tool is made of a single flattened piece of steel that is slightly bent and curved on each end. It is designed for removing and installing vehicle tires during repair or replacement. It helps pry tire beads away from the wheel rim, enabling safe and convenient tire removal, replacement, and maintenance. You have stated that the tire iron is manufactured entirely in Malaysia from raw carbon 40Cr steel that is sourced from China. The manufacturing processes that occur in Malaysia include cutting the raw steel to the required dimensions, forging, pressing, letter stamping, grinding, polishing, and chrome plating. Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP

Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). Regarding the country of origin of the tire iron, it is our view that raw steel is substantially transformed in Malaysia into a finished tool. As demonstrated in your production flow charts, all manufacturing and finishing operations occur in Malaysia. Therefore, the country of origin of the tire iron, item SP004, is Malaysia. The holding set forth above applies only to the specific factual situation and merchandise description as identified 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 the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border 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 periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Anthony Grossi at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division