RE: The country of origin of a ratchet tie-down

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 N364675 September 2, 2026 OT:RR:NC::N1:104 CATEGORY: Origin Gena Haddock Expeditors Tradewin 795 Jubilee Dr. Peabody MA 01960 RE: The country of origin of a ratchet tie-down Dear Ms. Haddock: In your letter dated August 27, 2026, you requested a country of origin ruling on a ratchet tie-down strap on behalf of your client, Tractor Supply Company. The product in question is a ratchet tie-down strap (SKU 6102155). The tie-down strap is used to secure cargo or equipment to the bed of a truck or trailer and to prevent it from shifting or moving during transport. It will be imported fully assembled and ready for retail sale. As imported the article will consist of a gear and pawl ratchet assembly comprised of a round gear with several teeth and two spring-loaded pawls that interact with the gear teeth, a center shaft, and a handle used to tension the strap. The article also includes a short length of woven polyester tie-down webbing, a long length of woven polyester tie-down webbing (approximately 2 in. x 27 ft.), two metal double-J end fittings incorporating magnets, sewing thread, labels, and retail packaging materials. The short strap is stitched at one end to a metal hook and attached at the other end to the ratchet assembly. The long strap is stitched at one end to a metal hook, and the other end is left free to be fed into the slot of the ratchet during use. The ratchet tie downs will be produced in two countries, China and Vietnam. The woven polyester tie-down webbing is produced in its entirety in Vietnam from spools of polyester yarn sourced in China. The webbing manufacturing process includes weaving the yarn on looms into the tie-down webbing of the specified width, construction, and break strength, creating a load-bearing textile from which the tie-down derives its rating. The woven webbing is then dyed to its specified color, and heat-set to stabilize the weave and fix the elongation characteristics of the finished webbing. The finished webbing is then cut on automatic cutting machines to the prescribed short and long lengths for each end of the tie-down, and the cut ends are heat sealed. The Vietnam-produced webbing is sent to China for assembly with the article’s other components. In China, the ratchet assembly and magnet hooks are entirely produced from Chinese-origin steel, the parts are heat treated, the molded plastic grip handle is injection molded, and the hardware is assembled. The Vietnam-produced webbing is combined with the Chinese-origin hardware, which entails feeding one end of the short webbing strap through a hook, folding and sewing it down, and the opposite end is attached to one
end of the ratchet assembly. The long length of webbing is fed through a hook, folded, and sewn down, and the free end is inserted through the slot in the ratcheting portion of the ratchet assembly. Finally, fabric identification and warning labels are sewn to the webbing, the product inspected, then packaged in retail packaging for export to the United States. 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). CBP has determined in similar country of origin scenarios that the essential character of ratchet tie-down straps is imparted by the webbing straps, as purchasers are buying the tie-down straps with rated break strengths to secure cargo. See, e.g., HQ H305503, dated February 20, 2020, and New York Ruling Letter N351767, dated August 7, 2025 (and rulings cited therein). In this case, the straps are produced in Vietnam from Chinese polyester yarn and maintain their name, character, and use as tie down straps after simple assembly in China with the Chinese-origin ratchet components. Accordingly, the country of origin of the complete ratchet tie-down straps will be Vietnam. 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 Arthur Purcell at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division