OT:RR:NC:N5:116
Shanshan Liang
Liang + Mooney, PLLC
2104 Delta Way, Unit 1
Tallahassee, FL 32303
RE: The country of origin and marking of nonalloy steel oil country tubular goods and nonalloy steel oil
country tubular goods with couplings
Dear Ms. Liang:
In your letter dated September 16, 2026, you requested a country of origin and a marking ruling on nonalloy
steel API 5CT oil country tubular goods (“OCTGs”) and nonalloy steel OCTGs imported with nonalloy steel
couplings on behalf of your client, Deep Oilfield Pipe Manufacturing (Cambodia) Co., Ltd. Photographs of
the proposed marking were included in your inquiry.
The products under consideration are nonalloy steel API5CT OCTGs and nonalloy steel OCTGs imported
with nonalloy steel couplings for use in oil and gas drilling and production operations. According to your
submission, the OCTGs and couplings will be imported into the United States (U.S.) in two different
scenarios: 1) OCTGs, specifically electric resistance welded (“ERW”) steel casing and tubing, imported
without couplings, and 2) OCTGs imported with Cambodian manufactured nonalloy steel couplings
preassembled.
In the first scenario, nonalloy steel coils of Chinese, South Korean, or Malaysian origin are sent to Cambodia
where they are slit, straightened, leveled, formed, and electric-resistance welded into tubes. These ERW tubes
are then heat treated, sized, straightened, inspected, tested, etc., prior to importation into the U.S. The tubes
are manufactured to API specifications.
In the second scenario, nonalloy steel coils of Chinese, South Korean, or Malaysian origin are exported to
Cambodia where they are slit, straightened, leveled, and welded into tubes. These ERW tubes are then upset
and heat treated on both ends, machined, and threaded. Next, an API 5CT coupling of Cambodian origin that
is manufactured from unfinished Chinese origin coupling stock that is cut to short lengths, internally and
externally turned, beveled, and threaded, is installed on the threaded tube ends. Finally, the OCTGs and
coupling are painted, marked, packed, and subsequently imported into the U.S.
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 U.S. 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.
A substantial transformation occurs when, as a result of manufacturing process, a new and different article
emerges, having a distinct name, character or use, which is different from that originally possessed by the
article or material before being subjected to the manufacturing process. See United States v.
Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940).
Based on the information provided, this office finds that the nonalloy steel coils and nonalloy steel API 5CT
couplings have been substantially transformed in Cambodia. Nonalloy steel coils of Chinese, South Korean,
or Malaysian origin are sent to Cambodia where they are slit and welded into tubes, a new product having a
distinct name, character or use. Regarding the API 5CT couplings, coupling stock of Chinese origin is sent to
Cambodia where it is cut, turned, beveled, and threaded, resulting in a new article (coupling) used
specifically to connect OCTGs. As such, the country of origin of the nonalloy steel OCTGs and the nonalloy
steel API 5CT couplings is Cambodia.
You provided photographs of your proposed marking which includes the words “Made in Cambodia” that are
stenciled on the steel tubes and couplings. 19 U.S.C 1304 (c) (1) requires that all pipe (iron, steel and
stainless steel), pipe and tube fittings (steel, stainless steel, chrome-moly steel or cast or malleable iron) shall
be marked to indicate the proper country of origin by one of five methods: die stamping, cast-in-mold
lettering, etching, engraving or continuous paint stenciling. The proposed marking of imported tubes and
couplings as described above, is conspicuously, legibly, and permanently marked in satisfaction of the
marking requirements of 19 U.S.C. 1304 and 19 CFR Part 134 and is an acceptable country of origin marking
for the imported tubes and the imported tubes with couplings.
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 Neil M. Cohen at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division