CLA-2-95:OT:RR:NC:N3:356
Scott Geftman
Larimar Logistics, Inc.
765 West Road
New Canaan, CT 06840
RE: The classification and country of origin of golf clubs
Dear Mr. Geftman:
In your letter dated June 16, 2025, you requested a ruling on the classification and country of origin of golf
clubs.
Information on component sourcing and descriptions of the manufacturing processes used to produce the
finished clubs were submitted with your inquiry.
FACTS:
The manufacturing operations for the golf clubs are as follows:
Scenario 1:
The club heads are produced in China from either titanium sourced in China, or stainless steel billets
sourced from Vietnam or another country in Asia. The club heads are exported to the Dominican
Republic.
The graphite shafts are produced in China and exported to the Dominican Republic.
The grips, of either rubber or thermoplastic rubber, are produced in either Taiwan or Malaysia and
exported to the Dominican Republic.
In the Dominican Republic, the shafts are cut and prepared to length and flex specifications, the heads
and shafts are bonded with epoxy, grips are installed, and various adjustment, calibration, balancing,
and cosmetic finishing operations are performed.
The finished clubs are labeled, packaged, and exported to the United States.
Scenario 2:
The club heads are produced in Vietnam from either titanium sourced in China, or stainless billets
sourced from Vietnam or another country in Asia. The club heads are exported to the Dominican
Republic.
The graphite shafts are produced in China and exported to the Dominican Republic.
The grips, of either rubber or thermoplastic rubber, are produced in either Taiwan or Malaysia and
exported to the Dominican Republic.
In the Dominican Republic, the shafts are cut and prepared to length and flex specifications, the heads
and shafts are bonded with epoxy, grips are installed, and various adjustment, calibration, balancing,
and cosmetic finishing operations are performed.
The finished clubs are labeled, packaged, and exported to the United States.
CLASSIFICATION:
You suggest that the classification of the finished goods is 9506.31.0000, Harmonized Tariff Schedule of the
United States (HTSUS). We agree.
The applicable subheading for the finished golf clubs will be 9506.31.0000, HTSUS, which provides for
"Articles and equipment for general physical exercise, gymnastics, athletics, other sports or outdoor games…
Golf clubs and other golf equipment; parts and accessories thereof: Golf clubs, complete.” The column one,
general rate of duty will be 4.4 percent ad valorem.
COUNTRY OF ORIGIN:
When determining the country of origin for purposes of applying the Section 301 trade remedies and other
additional tariffs, the substantial transformation analysis is applicable. 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, 69 C.C.P.A. 151 (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).
You suggest that the country of origin of the golf clubs produced under both scenarios is the Dominican
Republic, the country where they are assembled and finished. We disagree.
U.S. Customs and Border Protection (CBP) has previously held that the two components of a golf club that
impart its essential character are the head and the shaft (see Headquarters Ruling Letter (HQ) H313495, dated
December 2, 2020, which references HQ H563286, dated August 25, 2005). Further, CBP has previously
ruled that the assembly of already finished components into a golf club does not result in a substantial
transformation (see HQ H313495, which references HQ 734256, dated July 1, 1992).
In the first scenario, both the golf club heads and the shafts are produced in China. Therefore, for duty
purposes, the country of origin of the golf clubs produced as described in the first scenario is China.
In the second scenario, the golf club heads are produced in Vietnam and the shafts are produced in China.
Therefore, and in accordance with HQ H313495, for duty purposes, the countries of origin of the golf clubs
produced as described in the second scenario are Vietnam (the country of origin of the heads), and China (the
country of origin of the shafts). To the extent that the shafts are a product of China, their value may be
apportioned from the total of the golf clubs for purposes of duty assessment.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 9506.31.0000, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading
9506.31.0000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 9506.31.0000, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e.,
9903.88.15, in addition to subheading 9506.31.0000, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided
for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying
duty rates are provided at https://hts.usitc.gov/.
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 Regulations (19 C.F.R. 177).
Should it be subsequently determined that the information furnished is not complete and does not comply
with 19 CFR 177.9(b)(1), the ruling will be subject to modification or revocation. In the event there is a
change in the facts previously furnished, this may affect the determination of country of origin. Accordingly,
if there is any change in the facts submitted to Customs, it is recommended that a new ruling request be
submitted in accordance with 19 CFR 177.2.
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 Maryalice Nowak at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division