OT:RR:NC:N3:356
Ms. Kerry Wang
Braumiller Law Group PLLC
5220 Spring Valley Road, Suite 200
Dallas, TX 75254
RE: The country of origin of fishing rods
Dear Ms. Wang:
In your letter dated September 9, 2025, on behalf of your client, Composite Forge, LLC, you requested a
country of origin ruling on the Centra series of fishing rods for purposes of country of origin marking and the
application of trade remedy and additional duties. Photographs and drawings of representative models of the
rods and their components, bills of materials, and a description of the manufacturing processes used to
produce the rods were included with your inquiry.
The manufacturing operations are as follows:
Rod blanks are manufactured in the United States to required specifications (length, diameter, etc.) and
exported to China.
Handles, reel seats, line guides, and hook keepers are manufactured in China.
In China, the line guides are thread-wrapped onto the rod blanks, and the thread wraps are encapsulated with
epoxy.
Also in China, the handles, reel seats, and hook keepers are assembled onto the rod blanks.
The finished rods are exported to the United States.
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).
Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless
excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous
place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a
manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin
of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be
able to know by an inspection of the marking on the imported goods the country of which the goods is the
product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may,
by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should
influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940).
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.
U.S. Customs and Border Protection (CBP) has previously held that the component of a fishing rod that
imparts its essential character is the rod blank, and that the assembly of fishing rod components onto a rod
blank does not result in a substantial transformation of the rod blank (see Headquarters Ruling Letter (HQ)
H560115, dated March 7, 1997).
In the scenario you describe, the rod blanks are produced in the United States. Therefore, pursuant to HQ
560115, we find that the country of origin of the Centra series of fishing rods, as produced under the
circumstances you describe, is the United States. Accordingly, at the time of entry, the fishing rods need not
be marked with their country of origin and they will not be subject to trade remedy or other duties.
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 Maryalice Nowak at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division