OT:RR:NC:N1:164
Gloria Gao
Jackup International Company Limited
Room 1703, Yishi Mansion, No. 95 Zhongshan Bei Road
Nanjing City, 210009, Jiangsu Province
China
RE: The country of origin of automotive jack stands
Dear Ms. Gao:
In your letter dated July 10, 2025, you requested a country of origin ruling on automotive jack stands.
Product information was submitted with your request.
The items under consideration are described as powder coated iron and steel jack stands which support the
weight of a vehicle after lifting by another device. During use, the user adjusts the height of the jack stand’s
ratchet bar to meet the chassis of a raised vehicle. Once positioned, teeth on the ratchet bar engage a pawl
within the base to prevent the ratchet bar from falling. As a result, the extended ratchet bar remains in
position and the jack stand bears the weight of the raised vehicle. Additionally, the base of the stand is
constructed in a manner that provides stability through contact with the ground. The subject jack stands can
support a maximum load of 2 tons, 3 tons, and 6 tons depending on the model. The ratchet bar of the 2-ton
model is height adjustable from 10 5/16 in. to 16 7/16 in., the 3-ton model from 11 1/4 in. to 16 7/8 in., and
the 6-ton model from 15 in. to 23 11/16 in. The jack stands will be imported in pairs. Although not separately
requested, you propose classification of the jack stands in heading 7326, Harmonized Tariff Schedule of the
United States (HTSUS). We agree.
In your request, you state that the jack stands are assembled in Thailand using raw materials and components
manufactured in China and Thailand. In the 2-ton model, the cast iron pawl, steel base, and steel handle are
manufactured in China and the cast iron ratchet bar is manufactured in Thailand. In the 3 and 6-ton models,
the cast iron pawl, steel base, steel handle, and steel locking pin are manufactured in China, and the cast iron
ratchet bar is manufactured in Thailand.
After planning and raw material inspection processes, steel plate from China is cut and stamped to size using
steel plate shearing and laser cutting machines to produce the components of the steel base and locking pin.
In Thailand, the cast ratchet bar is manufactured and undergoes shot blasting. Also in Thailand, steel
components from China are welded to form the structure of the base assembly. Following that, the handle and
pawl are assembled, and all components are powder coated. Finally, the jack stands undergo final assembly
and packaging for export.
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).
Based on your described scenario and the submitted information, it is the opinion of this office that the
totality of manufacturing processes and assembly operations in Thailand substantially transform the
constituent components from China and Thailand. Before processing in Thailand, the raw materials and
components do not possess the physical characteristics necessary for use as a jack stand. Individually, the raw
materials and components are not capable of bearing the weight of a vehicle and maintaining its position by
providing an adjustable yet stable base of support. Following the manufacturing operations and assembly in
Thailand, the components lose their individual identities and a different article emerges with a new name,
character, and use. Accordingly, the country of origin is Thailand.
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
(C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division