OT:RR:NC:N5:137
Songzhou Jiang
Fengmao (Thailand) Co. LTD.
No.481, Group 2, Pananikhong Street,Nikhong Phatthana District
Rayong Province, Thailand
RE: The country of origin of rubber transmission belts
Dear Mr. Jiang:
In your letter dated August 28, 2025, you requested a country of origin ruling on rubber transmission belts
Item 1 is a timing belt. It is a synchronous belt composed of a layer of rubber incorporating glass fiber cord
with a layer of fabric on the teeth. The rubber is either hydrogenated nitrile butadiene rubber (HNBR) or
chloroprene rubber (CR) of Thai origin; the glass fiber cord is of either German or Japanese origin; and the
high elastic nylon fabric is of English or Japanese origin. The imported belt is ready for use and requires no
further processing after importation.
All manufacturing steps take place in Thailand. Compound rubber undergoes a calendaring process to adjust
the thickness of the sheet and incorporate the wedge (cogged) surface. Once the appropriate thickness is
obtained, the rubber sheet is fed onto a splicing machine. The product then undergoes the building process
where the cord is incorporated into the rubber, and the fabric is applied to the teeth. The slab is placed into a
vulcanizer to be cured at high temperature and pressure. After the slab is cooled it is placed on the grinding
machine to create a smooth surface. The slab undergoes a cutting process to create pieces according to
specifications. The belts are measured, inspected, and packed for shipment.
Item 2 is a cogged belt. It is a synchronous belt composed of a layer of rubber incorporating polyester cord
with a layer of fabric on the backside. The ethylene propylene diene monomer (EPDM) rubber is of Thai
origin, the polyester cord is of German or Japanese origin, and the backside fabric is of English origin. The
imported belt is ready for use and requires no further processing after importation.
All manufacturing steps take place in Thailand. Compound rubber undergoes a calendaring process to adjust
the thickness of the sheet and incorporate the wedge (cogged) surface. Once the appropriate thickness is
obtained, the rubber sheet is fed onto a splicing machine. The product then undergoes the building process
where the cord is incorporated into the rubber, and the fabric is applied to the backside. The slab is placed
into a vulcanizer to be cured at high temperature and pressure. After the slab is cooled it is placed on the
grinding machine to create a smooth surface. The slab undergoes a cutting process to create pieces according
to specifications. The belts are measured, inspected, and packed for shipment.
Item 3 is a serpentine belt (grinding belt). It is a belt with a trapezoidal cross-section (V ribbed belt)
incorporating between 3 and 20 ribs based on specifications. The belt is composed of a layer of smooth
(backside) EPDM rubber, a layer of polyester or nylon cord and a layer of ribbed EPDM rubber. The EPDM
rubber is of Thai origin; the polyester or nylon cord is of German or Japanese origin. The imported belt is
ready for use and requires no further processing after importation.
All manufacturing steps take place in Thailand. Compound rubber undergoes a calendaring process to adjust
the thickness of the sheet. Once the appropriate thickness is obtained, the rubber sheet is fed onto a splicing
machine. The product then undergoes the building process where the cord is wrapped between two layers of
rubber. The slab is placed into a vulcanizer to be cured at high temperature and pressure. After the slab is
cooled it is placed on the grinding machine to create a smooth surface. The slab undergoes a cutting process
to create pieces according to specifications. The belts are measured, inspected, and packed for shipment.
Item 4 is a serpentine belt (molded). It is a V-ribbed belt incorporating between 3 and 20 ribs based on
specifications. The belt is composed of a layer of fabric (backside), a layer of polyester or nylon cord, a layer
of EPDM rubber and a layer of fabric (rib-side). The fabric is of English or Japanese origin; the polyester or
nylon cord is of German or Japanese origin; and the EPDM rubber is of Thai origin. The imported belt is
ready for use and requires no further processing after importation.
All manufacturing steps take place in Thailand. Compound rubber undergoes a calendaring process to adjust
the thickness of the sheet. Once the appropriate thickness is obtained, the rubber sheet is fed onto a splicing
machine. The product then undergoes the building process where the backside fabric is wrapped on a sleeve,
the cord is wound onto the fabric, the rubber is wound over the cord. The final layer of fabric is placed into
the mold followed by the slab. The product undergoes vulcanization at high temperature and pressure. After
the slab is cooled it undergoes a cutting process to create pieces according to specifications. The belts are
measured, inspected and packed for shipment.
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).
The manufacturing steps, conducted in Thailand to produce the transmission belts, result in a substantial
transformation. Therefore, the country of origin of the transmission belts 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
(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 Christina Allen at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division