The country of origin of a tape measure

N362811
July 15, 2026
OT:RR:NC:N1:105
CATEGORY: Origin Fay Jin GreatStar Industrial USA, LLC 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The country of origin of a tape measure Dear Ms. Jin: In your letter dated July 2, 2026, you requested a country of origin ruling on a tape measure. Descriptive literature was provided for our review. The item under consideration is described as a tape measure, which is a versatile tool utilized by tradespeople, inspectors, contractors, homeowners, and various consumers for accurate and rapid distance measurement. Its compact, retractable design facilitates the measurement of both short and extensive lengths, while its portability allows for easy storage in a pocket or toolkit. The instrument features a 25-foot long, flexible yellow steel ruler tape marked with linear measurements in feet, inches, and fractions down to 1/32 inch. This flexible steel strip can conform to curves and corners. Internally, the tape coils around a plastic wheel housed within a plastic casing, driven by a metal spring mechanism that enables automatic retraction. Additional functionalities include a sliding button for locking the tape in position and a floating hook on the end for secure attachment during measurements. The tape measure is constructed of Chinese and Cambodian raw materials. The Chinese materials include the painted metal blade, shell encapsulation, push button, push knob with rubber coating, roller core cylinder, role core bottom, roll core cap, ruler spring, ruler hook, ruler pad, spacer plate, rivet, screws, and belt buckle. The tape casings are from Cambodia. The manufacturing process for the tape measure begins in China, where steel strips are precisely cut to the required width. These narrow strips then undergo heat treatment and receive a yellow base coating. The coated strips are then shipped to Cambodia, where the scale and numerical markings are applied via ink printing. The strips are then varnished, precision-cut to specified lengths, and fitted into a custom tape casing. Final assembly incorporates components sourced from China, such as the push button and hook, to produce the complete tape measure. 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 a

substantial 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 tape measure (similar to the subject merchandise in New York Ruling N358597), while the application of numerical markings on the metal tape is an essential step in its production as a measuring device, it is a simple process. The metal tape arrives pre-cut to specified dimensions and already bearing the finished, pre-painted yellow coating, meaning it can only be used to make tape measures. It is exported to Cambodia solely for the application of numerical markings and the simple assembly of Chinese components. Additionally, the process of combining the remaining Chinese components constitutes a minor cost, requires minimal time, and involves simple manufacturing processes. Thus, it does not effect a substantial transformation of the tape measure, imparting a new name, character, or use distinct from its state upon departure from China. Consequently, it is our determination that the country of origin of the tape measure is China, reflecting the origin of the predominant components. 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 Jason Christie at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division