OT:RR:NC:N4:424
Ms. Yun Je Lee
Delight E&C Customs Corporation
136 Jungang-daero, Jung-gu, Busan, Republic of Korea
Busan 48936 Korea, South
RE: The tariff classification and Country of Origin of golf balls
Dear Ms. Lee:
In your letter dated April 28, 2025, you requested a Country of Origin ruling for golf balls.
Photographs and descriptions were submitted for two different scenarios of exporting golf balls to the United
States.
In the first scenario, A. Corp, a parent company based in Korea, imports the raw material “core” for golf balls
from its subsidiary in China. The golf ball core is in an uncoated state where the raw materials are mixed and
cut, heat and pressure applied and buffed. The item is still not suitable to be used in the sport of golf. The
“raw fabric” is then shipped to A. Corp’s factory in Korea where it will go through a series of processing
steps including cover extrusion, injection molding, base coating, marking, final inspection and packaging, to
produce the finished golf ball which is then packaged and sent to the U.S.
In the second scenario, A. Corp’s Chinese subsidiary imports the raw material “golf ball core” for the golf
balls from Vietnam. The golf ball core is in an uncoated state where the raw materials are mixed and cut,
heat and pressure applied and buffed. The item is still not suitable to be used in the sport of golf. The “raw
fabric” is then shipped to A. Corp’s factory in China where it will go through a series of processing steps
including cover extrusion, injection molding, base coating, marking, final inspection and packaging, to
produce the finished golf ball which is then packaged and sent to the U.S.
The “country of origin” is defined in 19 CFR 134.1(b) 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 this part.
When determining the country of origin for purposes of applying current trade remedies under Section 301,
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 country of origin of the subject golf balls, in our view, further processing in the second country
results in a substantial transformation in that the raw fabric was transformed into a functioning golf ball. ?In
CASE 1, the country of origin would be Korea where in CASE 2 the country of origin would be China.
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 Roseanne Murphy at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division