OT:RR:NC:N1:103
Kensie Sugama
Trade Pacific PLLC
700 Pennsylvania Ave. SE, Suite 500
Washington, DC 20003
RE: The country of origin of a telehandler
Dear Ms. Sugama:
In your letter dated December 5, 2025, you requested a country of origin ruling on behalf of your client, PT
SANY Indonesia Mining Equipment.
The merchandise under consideration is identified as a telehandler, model number STH1056. The
telehandler’s specifications are identical to the machine described in New York ruling N352101, dated
August 27, 2025, which was manufactured by a related entity in Turkey. Moving forward, the telehandler
produced in Turkey will use the identifier STH1056-TUR and the unit manufactured in Indonesia will use the
identifier STH1056-IDR.
At the Indonesian facility, the telehandler will be produced using both domestic and foreign components. The
foreign components are sourced from China, Denmark, France, Germany, Hungary, India, Indonesia, Italy,
Japan, South Korea, and the United States. The major foreign subassemblies include a German engine, a
Hungarian transmission, a Chinese cab subassembly, a Japanese pump system, and Italian front and rear
axles.
The manufacturing process consists of three stages: frame subassembly production, boom section production,
and final assembly.
The frame subassembly production begins with creating intermediate shapes and forms referred to as
reinforcing plates, overlay plates, mounting bases, brackets, and other supports. The shapes are produced
using operational steps described as cutting rough shapes from steel plates, using a press to create the desired
geometries, machining the resulting pieces, and welding them together to form both flat and
three-dimensional components. Some of these components are then used to form an intermediate
subassembly referred to as a frame body. The next three steps are described as adding brackets that support
the cab, engine, cylinders, etc.; moving the assembly to a machining center where holes are drilled; and
painting the assembly.
In a separate area, four boom sections are produced using components sourced from India and Indonesia.
These subcomponents are referred to as various panels, reinforced plates, boards, tubes, supporting rails,
shafts, and more. In Indonesia, the main body of each boom section is created by laser cutting a rough shape
from a steel plate then bending it into a tube-like form. Depending on the boom section, the required
brackets, reinforcement plates, cylinder supports, roller supports, sleeves, ears, etc., are welded to the body.
The resulting assembly is then shot blasted and painted.
Final assembly begins with installing various valve assemblies (e.g., telescopic valve assembly, main pump
assembly for the brake system, steering valve assembly, etc.) to the frame subassembly. Afterwards, workers
incorporate the driving system, which involves installing the front and rear axles, rims, tires, and drive shaft.
The frame continues along to the next station, where the counterweight and outrigger assembly are mounted
to the frame. After that, workers install the engine, transmission, and other related components for the
powertrain, such as the radiator, air intake system, exhaust system, and fuel system. At the next station, the
cab assembly is lifted onto the frame and bolted in place. Next, the boom assembly is installed, which
involves installing a slider assembly to each boom section, nesting and linking the sections together,
installing the hydraulic system, and attaching a fork-like attachment. Lastly the telehandler is inspected,
tested, and painted.
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).
Based upon your description of the manufacturing operations, the nature of the processing performed in
Indonesia is not simple. In addition to the final assembly occurring in Indonesia, two of the major structural
subassemblies (i.e., the frame assembly and the boom assembly) are manufactured from common metal
forms (e.g., metal sheets, plates, and tubing) and transformed into integral subassemblies in Indonesia. The
combined operations result in the individual parts losing their separate identities to become a new article.
Thus, based on the totality of the circumstances, the country of origin of the telehandler, model number
STH1056-IDR, will be Indonesia.
The merchandise in question may be subject to antidumping duties and countervailing duties (AD/CVD).
Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance
office in the International Trade Administration of the Department of Commerce and are separate from tariff
classification and origin rulings issued by Customs and Border Protection (CBP). You can contact them at
https://trade.gov/enforcement/ (click on “Contact Us”). For your information, you can view a list of current
AD/CVD cases at the United States International Trade Commission website at
https://www.usitc.gov/trade_remedy/documents/orders.xls, and you can search AD/CVD deposit and
liquidation messages using CBP’s AD/CVD Search tool at https://aceservices.cbp.dhs.gov/adcvdweb.
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 Paul Huang at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division