CLA-2-84:OT:RR:NC:N1:104
Christopher Hay
Aerofast Tiedowns Ltd.
2 Shivas Place,
Christchurch 8052
New Zealand
RE: The tariff classification and country of origin of ratchet tie downs
Dear Mr. Hay:
In your letter dated November 4, 2025, you requested a tariff classification and country of origin
determination ruling.
The product in question is a pair of two marine transom tie down straps, item number TRHH-1.5-4. The tie
downs consist of a gear and pawl-type ratchet mechanism with a lever handle for tensioning, two woven
polypropylene webbing straps, and two rubber-coated metal S-hooks attached to the ends of the webbing
straps. The tie downs are used to secure a boat to a trailer during transportation and will be produced from
materials and components from three countries, China, New Zealand, and South Korea. Your submission
includes a manufacturing flowchart, a description of the processing, and a bill of materials. In New Zealand,
South Korean polypropylene yarn is woven on weaving machines into tie-down webbing, cut to length, and
the ends sealed to prevent fraying. Next, in New Zealand, a Chinese origin ratchet mechanism and hooks are
assembled to the webbing using sewing machines. Finally, the tie downs are packaged in an export carton.
The applicable subheading for the ratchet tie downs will be 8479.89.9599, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for Machines and mechanical appliances having individual
functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical
appliances: Other: Other: Other. The general rate of duty is 2.5 percent ad valorem.
Country of Origin
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.”
When determining the country of origin, the substantial transformation analysis is applicable. 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 down
straps is imparted by the webbing straps. See HQ H305503, dated February 20, 2020, and New York Ruling
Letters N343501, dated November 22, 2024, and N316901, dated February 4, 2021. In this case, the straps
are produced in New Zealand from South Korean polyester yarn and maintain their name, character, and use
as tie down straps after simple assembly in New Zealand with the Chinese origin ratchet and hook
components. Accordingly, the country of origin of the complete ratchet tie down straps, will be New Zealand.
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 of New Zealand
will be subject to an additional ad valorem rate of duty of 15 percent. At the time of entry, you must report
the Chapter 99 heading applicable to your product classification, i.e. 9903.02.46, in addition to subheading
8479.89.9599, HTSUS, listed above.
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 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division