OT:RR:NC:N3:356
Connor Summers
Black Sheep Custom Tackle
5404 Clearwater Road North
Baxter, MN 56425
RE: The country of origin of fishing jigs
Dear Mr. Summers:
In your letter dated November 19, 2025, you requested a country of origin ruling on fishing jigs for marking
purposes and the application of trade remedies and additional duties. Photographs of the completed jigs and
their components, information regarding the components of each jig, and a description of the processes
performed to produce the completed jigs were submitted with your inquiry.
FACTS:
The goods at issue are jigs used in the sport of fishing. You have requested a ruling on two styles of jig: Item
1, “Non-Skirted Tungsten Jig,” comprised of a jig head, hook, wire keeper, and eye; and Item 2, “Skirted
Tungsten Jig,” comprised of a jig head, hook, wire keeper, skirt, and weed guard.
You state that the manufacturing operations used to produce the jig heads are as follows:
Tungsten heads, featuring slits into which hooks may be inserted, are produced in China and exported to the
Dominican Republic.
Metal fishing hooks for Item 1 are produced in Thailand and exported to the Dominican Republic.
Metal fishing hooks for Item 2 are produced in France and exported to the Dominican Republic.
Plastic eyes for Item 1 are sourced from the United States and exported to the Dominican Republic.
Rubber skirting material for Item 2 is produced in China and exported to the Dominican Republic.
Silicone skirting material for Item 2 is produced in Vietnam and exported to the Dominican Republic.
A weed guard for Item 2, composed of nylon and additional unidentified fibers, is produced in the United
States and exported to the Dominican Republic.
In the Dominican Republic, the fishing hooks are inserted into the slits in the jig heads and the two
components are welded together to create jig assemblies.
Wire keepers, produced in the Dominican Republic, are welded to the jig assemblies.
The jig assemblies are painted.
The eyes are glued to Item 1.
The skirts are produced from the skirting materials and attached to Item 2.
The weed guards are glued to Item 2.
The completed jig heads are packaged for retail sale.
LAW AND ANALYSIS:
When determining the country of origin for purposes of applying current trade remedies 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).
In deciding whether the combining of parts or materials constitutes a substantial transformation, the
determinative issue is the extent of operations performed and whether the parts lose their identity and become
an integral part of the new article. Belcrest Linens v. United States, 573 F. Supp. 1149 (Ct. Int’l Trade 1983),
aff’d, 741 F.2d 1368 (Fed. Cir. 1984). Assembly operations that are minimal or simple, as opposed to
complex or meaningful, will generally not result in a substantial transformation. If the manufacturing or
combining process is a minor one that leaves the identity of the article intact, a substantial transformation has
not occurred. Uniroyal, Inc. v. United States, 3 C.I.T. 220, 542 F. Supp. 1026 (1982), aff’d 702 F.2d 1022
(Fed. Cir. 1983).
Of the components of each of the subject fishing jigs, the only two necessary to produce a completed jig are
the jig head and the fishing hook. Although a wire keeper may be a helpful addition to a jig, research in this
office indicates that it is not strictly necessary in order for the jig to be functional. Further, the remaining
components (i.e., skirts, eyes, and weed guards) are optional additions to the completed jigs.
You argue that the welding of the hook into the jig head is a complex process that effects a substantial
transformation. However, U.S. Customs and Border Protection has previously held that welding is a simple
assembly operation that does not amount to a substantial transformation (see, e.g., Headquarters Ruling
Letter H302252, dated February 27, 2019, and NY Ruling Letter N353884, dated October 10, 2025). Both
the jig head and the hook retain their separate identities when welded together. Further, welding the wire
keepers to the jigs, painting the jigs, and attaching a skirt, weed guard, or eyes do not amount to a substantial
transformation.
HOLDING:
For marking purposes, as well as for the application of trade remedies and additional duties, the countries of
origin of the completed jigs are as follows:
Item 1 – China (the country of origin of the jig head) and Thailand (the country of origin of the hook)
Item 2 – China (the country of origin of the jig head) and France (the country of origin of the hook)
Further, the country of origin of the wire keepers of both items, and the skirt of Item 2, is the Dominican
Republic.
Finally, if, as you claim, the country of origin of the plastic eye of Item 1 and the weed guard of Item 2 is the
United States, these components need not be marked with their country of origin and neither is subject to
trade remedies or additional 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division