RE: The country of origin of rubber mallets

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364338 September 14, 2026 OT:RR:NC:N5:137 CATEGORY: Origin Gary Xu Meridian International Co., Ltd. 1886 Laiyin Road, Sonjiang, Shanghai, China. Shanghai 201615 China RE: The country of origin of rubber mallets Dear Mr. Xu: In your letter dated August 17, 2026, you requested a country of origin ruling on rubber mallets The imported mallets are identified as 16-ounce Husky Fiberglass handle white and black rubber mallet, SKU #1006100802; and 24-ounce Husky Fiberglass Handle Gray Rubber Mallet, SKU number 1006432316. Each mallet consists of s styrene-butadiene rubber (SBR) hammer head and a fiberglass, plastic coated handle. The mallets are intended for use in damage-free tamping tasks associated with tile installation, furniture assembly, carpentry, automobile repair, etc. You have stated that each mallet is manufactured in the same manner. The rubber hammer heads are manufactured in Thailand from inputs originating in Thailand. The fiberglass handles are manufactured in China from inputs originating in China. The final assembly of the rubber hammer heads with the fiberglass handles takes place in China. The detailed manufacturing process is as follows: Rubber Hammer Head production process in Thailand: 1) Rubber compound mixing: Pre-weighed bales of SBR copolymer, originating in Thailand, are loaded into the internal mixer and ground. Fillers, pigment, process aid and rubber accelerator, all originating in Thailand, are added and mixed together until uniform dispersion is achieved. 2) Final mixing (Curative incorporation): The resulting masterbatch is fed into the open two-roll mixing mill. Once the compound bands around the rolls, sulfur, a vulcanizing agent, vulcanization activators, and scorch retarders are added evenly across the sheet. The compound is repeatedly cut, folded into triangular packages and passed through the rolls until fully dispersed. The mixed compound is sheeted to a uniform thickness, then laid flat to cool, then stored for the next operation.
3) Precision Pre-forming (Blank Cutting): The compounded rubber sheet is rolled into a cylindrical charge and loaded into the pre-forming machine. The target blank weight is set on the controller. The machine extrudes and cuts the compound into uniform pre-weighed blanks. The cut blanks are placed on racks/staging trays and held for the subsequent molding operation. 4) Compression molding and Vulcanization (Hammer Head Forming): The press is set to the temperature and cure time specified for each SKU number. Once the mold reaches the set temperature, the pre-formed blank is placed in the mold cavity, the mold is closed, and pressure is applied to vulcanize and form the rubber into the hammer-head shape. After curing, the mold is opened, the molded head is demolded and a visual appearance inspection in performed. The finished hammer heads are packaged and shipped to China for final assembly. Fiberglass Plastic-Coated Handle production process in China: 1) Fiberglass core rod forming: Continuous fiberglass roving and liquid polyester resin are fed into the pultrusion machine together. The composite material is pulled through a heated die and cured at a fixed temperature and traction speed to form a solid, straight fiberglass core rod of standard diameter. The long rods are cut to fixed lengths matching product specifications. 2) First coating: white polypropylene (PP) injection and logo molding: The fiberglass core rod is placed into the first injection mold. White PP material is injected to form the first coating and integrated brand logo. After molding, the semi-finished handle is cooled and shaped for subsequent operations. 3) Second coating: black PP injection: The white PP with logo, semi-finished handle is placed into the second mold. Black PP material is melted and secondarily injected over the outer layer of the white PP base. The black PP layer covers the designated area and forms the main outer plastic structure of the handle. The handle is cooled and fixed after processing. 4) Third coating: Thermoplastic elastomer (TPE) tail injection: Load the double-layer PP coated handle, semi-finished product into the third-set coating mold. Heat and melt the TPE materials and perform targeted injection coating on the tail section of the handle. This coating forms a non-slip, wear-resistant and flexible TPE layer at the handle tail. Final assembly and packaging process in China: Input materials: Rubber hammer head (manufactured in Thailand) and Fiberglass plastic-coated handle (manufactured in China) 1) Adhesive applied to the connecting end of the handle. 2) The handle is press-fitted firmly into the reserved mounting hole of the rubber hammer head. 3) A plastic fastening ring is installed around the exterior of the joint to reinforce the connection and prevent loosening or separation during use. 4) Product labels are affixed as required by the customer. 5) Final inspection and sorting of all finished goods are conducted. 6) The finished mallets are packed into standard cartons for shipment. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, 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). Additionally, 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. It is our opinion that the rubber mallet head imparts the essence of the finished mallet. In Thailand, the mallet heads are molded and take on the shape and size of the finished mallet heads. Based on the provided description and pictures of the assembly and finishing operations performed in China, the mallet heads are not substantially changed so as to transform it into a new article with a different name, character, or use. Additionally, the mallet heads are not substantially transformed by the attachment of the handles. Therefore, the country of origin of both the rubber mallets will be Thailand. The rubber mallets are appropriately marked “Made in Thailand” or “Product of Thailand”. 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 Christina Allen at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division