OT:RR:NC:N5:116
Michael Anzalone
Precision Signs.com, Inc.
243 Dixon Ave.
Amityville, NY 11701
RE: Country of origin and marking of plastic and aluminum components from China to be assembled in the
United States
Dear Mr. Anzalone:
In your letter dated April 28, 2026, you requested a country of origin ruling for the purposes of marking
plastic and aluminum components from China for use in the assembly of non-illuminated signage products
manufactured in the United States (U.S.). The articles from China are described as an aluminum extrusion
made from Aluminum Alloy 6063 (Al-Mg-Si), an injection-molded mounting bracket body, an
injection-molded mounting bracket core, and an injection-molded sign frame body, all used in the
construction of complete signage assemblies.
You explain that the plastic and aluminum components from China are designed to be used solely in the
manufacture of complete signage assemblies and will not be sold in their condition as imported. Specifically,
the imported components from China are assembled with U.S.-made components to create custom signage
assemblies tailored to your customers' exact specifications. Descriptive information and flow charts were
provided.
You request the subject aluminum and plastic components be excepted from individual marking since they
are substantially transformed by machining and/or assembly operations performed by your company in the
U.S. and that Precision Signs is the ultimate purchaser of these imported components.
The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless
excepted, every article of foreign origin (or its container) imported into the U.S. 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 U.S. the English name of the country
of origin of the article. Part 134, Customs Regulations (19 CFR Part 134) implements the country of origin
marking requirements and exceptions of 19 USC 1304.
Section 134.1(d) defines the ultimate purchaser as generally the last person in the U.S. who will receive the
article in the form in which it was imported. 19 CFR 134.1(d)(1) states that if an imported article will be
used in manufacture, the manufacturer may be the ultimate purchaser if the manufacturer subjects the
imported article to a process which results in a substantial transformation of the article. The case of U.S. v.
Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940), provides that an article used in manufacture
which results in an article having a name, character or use differing from that of the constituent article will be
considered substantially transformed and that the manufacturer or processor will be considered the ultimate
purchaser of the constituent materials. Pursuant 19 CFR 134.35, in such circumstances, the imported article is
excepted from marking and only the outermost container is required to be marked.
Based on the information provided, we find that Precision Signs is the ultimate purchaser of the subject
plastic and aluminum components. In accordance with 19 CFR 134.35, the aluminum extrusion made from
Aluminum Alloy 6063 (Al-Mg-Si), an injection-molded mounting bracket body, an injection-molded
mounting bracket core, and an injection-molded sign frame body sourced from China are used by Precision
Signs in the assembly of non-illuminated signage products manufactured in the U.S. and not sold separately
in their condition as imported, are excepted from individual marking. Only the outermost containers of the
imported articles must be marked with country of origin of China.
Please be advised that aluminum extrusions may be subject to antidumping duties and/or 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 (ITA) and
are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP).
General information regarding the ITA and AD/CVD can be found at
https://www.trade.gov/us-antidumping-and-countervailing-duties. The ITA’s “Guide on How to File for an
Antidumping/Countervailing Duty Scope Ruling Request” is available at
https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf.
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 Regulations (19 CFR Part 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, contact
National Import Specialist Neil M. Cohen at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division