OT:RR:NC:N1:118
Jessica Islas-Parker
A. N. Deringer
173 West Service Rd.
Champlain, NY 12919
RE: The country of origin of a Broadcast Spreader
Dear Ms. Islas-Parker:
In your letter dated February 24, 2026, on behalf of your client, Meridian International Co., Ltd., you
requested a country of origin ruling on a Broadcast Spreader and a Handheld Spreader. Pictures of the
merchandise in different stages of manufacture were included with your submission, along with
manufacturing flow charts. Please note that our office will address the Handheld Spreader in a separate
letter.
The Broadcast Spreader is a wheel-driven centrifugal spreading device that is used to disperse materials such
as seeds and fertilizers over large lawns and farmlands. When the user pushes the device forward, two large
wheels roll along the ground and directly drive a spreading plate/disc that is located below the hopper. The
spreading plate/disc rotates at a high speed through an internal transmission mechanism (gears or shafts). The
flow rate of the material being spread is controlled by adjusting the opening of the hopper gate at the bottom
via a control lever on the handle. The material falls from the opening at the bottom of the hopper onto the
rotating plate/disc below. The high-speed rotating plate/disc uses centrifugal force to project the material
outward in all directions, forming a uniform fan-shaped or band-shaped coverage. The forward speed of the
wheels is directly related to the rotational speed of the plate/disc, so the user’s walking speed will affect the
application rate per unit area and the coverage width.
You have stated that the manufacturing process for the Broadcast Spread begins in Cambodia, where raw
plastic materials are used for the injection molding of the following subcomponents: hopper, wheels, top cap
of gear box, spread plate/disc, and gear. In China, raw plastic materials are used for the injection molding of
the subsequent subcomponents: gear box (bottom), gear box sheath, triangular nut, adjusting nut, material
discharge opening, material discharge control plate, discharge flap, rate control dial, control housing (top and
bottom), gear adjustment block, trigger, washer, shaft pin, wire control, wire control slider, rate control slider,
wheel cap, and steel tube cap. Also in China, metal is punched and bent into the metal axle, metal handles,
metal foot, metal support, metal connection part, metal connection rod, and metal control housing. The metal
handles are then welded together and powder coated. Next, the Cambodian subcomponents (i.e., the hopper,
wheels, top cap of gear box, spread plate/disc, and gear) are shipped to China and manually assembled with
the Chinese subcomponents. Finally, the finished Broadcast Spreader is packaged for retail sale before
shipment 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. Friedlaender & 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.
Regarding the Broadcast Spreader, it is our view that the Cambodian subcomponents (i.e., the hopper,
wheels, top cap of gear box, spread plate/disc, and gear) perform the essential function of the finished
spreader. The hopper holds the material being spread and the spread plate, gear and wheels disperse the
material. It is our opinion that these subcomponents do not lose their identity or character when assembled
with the Chinese subcomponents. Therefore, the country of origin of the Broadcast Spreader is Cambodia.
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 Anthony Grossi at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division