RE: The classification, country of origin, marking, and eligibility of the United States-Mexico-Canada Trade Agreement (USMCA) of a high security type bolt seal.

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 N364405 September 17, 2026 OT:RR:NC:N5:121 CATEGORY: Origin ShunTao Yu Yoxing Technology Mexico SA de CV Lot 34-35, Capithal Park Colotlan, sobre Carretera a Colotlan #1460, C.P. 45200 Zapopan 45200 Mexico RE: The classification, country of origin, marking, and eligibility of the United States-Mexico-Canada Trade Agreement (USMCA) of a high security type bolt seal. Dear Mr. Yu: In your letter dated August 19, 2026, you requested a classification, country of origin, marking, and eligibility of the USMCA ruling on a high security type bolt seal. Photographs and descriptions of the merchandise and manufacturing processes were included in your inquiry. The article under consideration is described as an ISO 17712 High Security (“H”) type bolt seal. It is a single-use high-security container bolt seal designed to secure ISO intermodal and ocean freight containers. The seal consists of a zinc-plated SAE 1008 steel pin and lock body containing a steel bushing, an open steel locking ring, a molded PC/ABS locking sleeve, and an ABS overmolded exterior body. In use, the steel pin is inserted into the lock body, and the seal becomes permanently locked. The seal must be cut or broken to be removed. It has a unique serial number and may also include a barcode, QR code, and customer/company logo for traceability and tamper-evidence purposes. The steel pin, bushing, and locking ring provide the essential locking function, and the molded plastics form the body and the tamper-evident exterior. It weighs approximately 58 grams. Classification The applicable subheading for the ISO 17712 High Security (“H”) type bolt seal will be 8309.90.0080, HTSUS, which provides for Stoppers, caps and lids (including crown corks, screw caps and pouring stoppers), capsules for bottles, threaded bungs, bung covers, seals and other packing accessories, and parts thereof, of base metal: Other: Other: Of steel. The general rate of duty will be 2.6 percent ad valorem. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at and the Trade Remedies page at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service https://www.cbp.gov/trade/programs-administration/trade-remedies Country of Origin and Marking You describe a manufacturing process in which the steel pin and steel bushing are produced in Vietnam, and the open steel locking ring is sourced from China. Those items are shipped to Mexico where the locking sleeve is injection molded and then assembled with the steel bushing and open steel locking ring to create the lock body. The pin and the lock body are positioned in dedicated tooling and then overmolded to create the finished seal body. The completed product is then marked/serialized, inspected for locking function and quality, packaged in Mexico, and exported to the United States. 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). 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. Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in sections 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining the country of origin of a good for marking purposes, with the exception of textile and apparel goods which are subject to the provisions of 19 CFR 102.21. See 19 CFR 102.11. Applied in sequential order, 19 CFR 102.11(a) provides that the country of origin of a good is the country in which: (1) The good is wholly obtained or produced; (2) The good is produced exclusively from domestic materials; or (3) Each foreign material incorporated in that good undergoes an applicable change in tariff classification set out in Part 102.20 and satisfies any other applicable requirements of that section, and all other applicable requirements of these rules are satisfied. These high security bolt seals are neither “wholly obtained or produced” nor “produced exclusively from domestic materials.” Therefore, paragraphs (a)(1) and (a)(2) cannot be used to determine the country of origin of these articles, and paragraph (a)(3) must be applied next to determine the origin of the finished articles. As indicated above, the finished seals are classified under heading 8309.
The tariff shift requirement in part 102.20 for the articles of heading 8309 at issue states, “A change to heading 8309 through 8310 from any other heading, including another heading within that group” Here, the individual components and materials used in the production of the high security type bolt seal are classified under various tariff headings other than subheading 8309, HTSUS. Upon assembly and integration in Mexico, the finished product is classified under HTSUS 8309.90.0080, as seals and other packing accessories…: Other: Other: Of steel. Therefore, the finished high security bolt seal meets the tariff shift. As a result, Part 102.11(a) applies. Accordingly, the country of origin of the high security bolt seal for marking purposes will be Mexico. As such, your proposed marking of ‘Made in Mexico’/Hecho en Mexico’ is appropriate per the applicable regulations. USMCA: The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act. General Note (“GN”) 11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states, in relevant part: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a “good originating in the territory of a USMCA country” only if-- (i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; (ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; (iii) the good is a good produced entirely in the territory of one or more USMCA countries using non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o)) … The subject high security bolt seals contain non-originating materials and are not considered a good wholly obtained or produced entirely in a USMCA country under GN 11(b)(i). Moreover, under GN 11(b)(ii), the high security bolt seals are not a good produced entirely in Mexico from originating materials. Therefore, we must next determine whether the non-originating materials undergo the tariff shift and satisfy other applicable requirements provided form in GN 11(b)(iii) and GN 11(o). As the high security bolt seals classified under subheading 8309.90.0080, HTSUS, the applicable tariff shift rule for goods classified in heading 8309 is GN 11(o), which provides in relevant part: “A change to headings 8309 through 8310 from any other chapter.” Since all the foreign-origin parts are classified outside of heading 8309, HTSUS, the requisite tariff shift rule is met, and the finished high security bolt seals are considered originating goods under the USMCA and eligible for preferential treatment. 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 Jennifer Jameson at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division