OT:RR:NC:N1:103
Tracy Evans
FOCUS Business Solutions, Inc.
6995 Monroe Boulevard
Taylor, MI 48180
RE: The country of origin of vibratory rollers
Dear Ms. Evans:
In your letter dated May 5, 2026, you requested a country of origin ruling on behalf of your client, Third
Coast Equipment Inc.
The subject vibratory rollers are identified as steel drum soil and asphalt vibratory rollers, which include
Double Drum Asphalt Rollers (models RA29 and RA45) and Single Drum Soil Rollers (models RS35, RS50,
and RS70). The Double Drum Asphalt Rollers are described as articulating rollers with a vibratory drum and
are designed for compacting and smoothing asphalt surfaces. The Single Drum Soil Rollers are described as
articulating rollers with a vibratory drum and rear pneumatic tires. They are used to compact soil during the
construction of parking lots, roads, and warehouses. Both categories of vibratory rollers are manufactured
using the same process.
Final assembly occurs in Japan. A front drum assembly, manufactured in Japan and comprising a steel drum
and vibratory mechanism, is mounted to a rear frame assembly. The rear frame assembly, produced in China,
serves as the frame and chassis of the vibratory roller and contains the engine, hydraulic system, fuel tank, oil
tank, drive system, canopy, and control system. These components are incorporated into a structural frame in
China, which is then shipped to Japan for final assembly.
The final assembly process involves mounting the drum assembly to the rear frame assembly, attaching the
drive motor, connecting the hydraulic hoses, filling the hydraulic oil tank and purging air from the system,
pressure testing the oil reservoir for leaks, and greasing all joints and fittings. Once assembly is complete,
vibration, driving, and safety tests are performed.
When determining the country of origin for purposes of applying current trade remedies under Section 301,
Section 232, 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 your submission, you argue that the country of origin of the finished vibratory rollers should be based on
the origin of the drum assembly. As described above, the vibratory rollers will be assembled by combining
two assemblies. While the Japanese drum assembly is an important component, the Chinese rear frame
assembly contains numerous structural, mechanical, and electrical systems that are integral to the operation
of the final machine. They include the chassis, control system, propulsion system, power drive systems, and
other key components. This assembly accounts for a significant portion of both the value and the number of
components in the finished machine. Thus, based on the totality of the circumstances, the country of origin of
the Double Drum Asphalt Rollers (models RA29 and RA45) and Single Drum Soil Rollers (models RS35,
RS50, and RS70), will be China.
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)
James P. Forkan
Director
National Commodity Specialist Division