OT:RR:NC:N1:104
Bo Shao
Wolit (Thailand) Co., Ltd.
178 Moo 1, Khlong Tamru
Mueang Chonburi, Chonburi 20000
Thailand
RE: The country of origin of ratchet tie downs
Dear Bo Shao:
In your letter dated August 19, 2025, you requested a country of origin ruling.
The products in question are five styles of ratchet tie downs, each consisting of a gear and pawl ratchet
buckle mechanism with a lever handle for tensioning, woven polyester webbing straps, and two metal hooks
(S-hooks or double J-hooks) attached to the ends of the webbing strap. The ratchet tie downs are used to
secure cargo and loads during transportation. The items will be produced in two countries, China and
Thailand. Your submission included a manufacturing flowchart, a description of the processing, a Bill of
Materials, and product specifications. The five ratchet tie downs are functionally the same with varying strap
widths (between 1-2 inches) and different working load limits (300, 500, 1,000, 1,666, and 3,333 lbs.).
In Thailand, spools of Chinese-sourced polyester yarn are woven into tie-down webbing, then dyed, cut, and
inspected. Next, in Thailand, steel plates of Chinese origin are stamped and pressed into ratchet gears,
handles, and frames, followed by zinc plating and powder coating. The webbing, ratchet buckle, and hooks
are assembled in Thailand using industrial sewing machines and riveting processes. Finally, the ratchet tie
downs undergo load-capacity testing, final inspection, and packaging in Thailand, with the outer packaging
marked with the labels containing the words “Made in Thailand.”
The “country of origin” is defined in Section 134.1(b) of the U.S. Customs and Border Protection (CBP)
Regulations (19 CFR 134(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 to render such other country the ‘country of origin’ within the meaning of this
part.”
The substantial transformation test is also used to determine the country of origin for the purposes of Section
301 measures and other duties. See, e.g., Headquarters Ruling Letter (HQ) 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 like ratchet
tie-downs is imparted by the webbing straps, as purchasers are buying the tie down straps to secure their
cargo. See HQ H305503, dated Feb. 20, 2020, and New York Ruling Letters N343501, dated Nov. 22, 2024,
and N316901, dated Feb. 4, 2021. 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 Thailand with
the Chinese origin ratchet components. Accordingly, the country of origin of the complete ratchet tie downs
will be Thailand.
You did not specifically request a marking ruling. In any case, you did not provide a sample image of a
proposed country of origin marking label, its font size, the type of label, or its proximity to other words on
the packaging, which may be needed to make a marking determination. Note that country of origin markings
must comply with the Customs laws and regulations, 19 U.S.C. 1304 and 19 CFR 134. See also 19 U.S.C.
1304. Any exception to the marking requirements for outermost container marking must comply with 19
CFR 134.22 and 134.32.
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 the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. If 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 Arthur Purcell at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division