RE: The country of origin of helical coil springs

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 N365349 October 9, 2026 OT:RR:NC:N1:113 CATEGORY: Origin Ogbo Ossai Stinson LLP 2200 Ross Ave, Suite 2900 Dallas, TX 75201 RE: The country of origin of helical coil springs Dear Mr. Ossai: In your letter dated September 23, 2026, you requested a country of origin ruling on helical coil springs on behalf of your client, Silgan Dispensing Systems Corporation. Informational material was submitted with your request. The products under consideration are helical coil springs. The springs are made from steel wire supplied by various vendors located in China, the European Union, India, South Korea, and Vietnam. Upon importation, the wire is shipped to a manufacturing facility in the United States where the wire is converted into springs. At this facility, the imported wire is fed through a machine which winds the wire around a mandrel forming springs and then cuts them at their required length. The newly cut springs are then sent to an oven to undergo heat treatment, improving durability and reducing internal strain from the coiling process. The springs are then rinsed and cleaned through a series of chemical and hot water baths. Lastly, the springs are allowed to cool and dry resulting in the final product, to be packed and shipped. 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). In this case, the steel wires used to make the springs are imported into the United States as reels or spools. During the manufacturing process, the steel wires are coiled around a mandrel and cut to specifications. From there, the steel wire transforms from a straight steel wire into a spiral of successive coils capable of elastically expanding and contracting under force. A straight steel wire is incapable of functioning in this manner due to the absence of successive coils which form the identifiable and functional shape of a helical coil spring. It is the opinion of this office that during the manufacturing process in the United States, the steel wire is transformed into an article with a new name, character, and use than what was present prior. It is transformed from a steel wire, incapable of expanding and contracting as a spring, into a helical coil spring. Accordingly, the country of origin of the helical coil springs for marking purposes is the United States. If a good is determined to be an article of U.S. origin, it is not subject to the country of origin marking requirements of 19 U.S.C. §1304. Whether an article may be marked with the phrase “Made in the USA” or similar words denoting U.S. origin, is an issue under the authority of the Federal Trade Commission (FTC). We suggest that you contact the FTC Division of Enforcement, 600 Pennsylvania Avenue, N.W., Washington, D.C. 20580 on the propriety of proposed markings indicating that an article is made in the U.S. 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. 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 Matthew Gay at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division