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