OT:RR:NC:N1:105
Icey Huang
Autowin Group Limited
Flat/RM 08, 15/F
Witty Commercial Building
1A-1L Tung Choi Street
Mongkok, Kowloon, Hong Kong
China
RE: The country of origin of a pencil tire gauge
Dear Ms. Huang:
In your letter dated October 1, 2026, you requested a country of origin ruling on a pencil tire gauge.
Descriptive literature was provided for our review.
The item under consideration is described as a pencil tire gauge (item number 1121200011), which is a
mechanical instrument designed to measure and indicate the internal air pressure of pneumatic tires. The item
is imported as a complete, fully assembled unit and has a chrome-plated stainless steel outer sleeve tube, a
PA66 (polyamide 66) air chuck head, a PA66 plastic indicator scale rod, and a stainless-steel pocket clip.
Internally, the gauge houses a rubber O-ring, a rubber piston/stopper, a stainless-steel compression spring,
and a PA66 piston guide sleeve. In operation, the PA66 air chuck head is pressed against a tire valve stem,
allowing pressurized air to enter the tube and force the rubber piston against the stainless-steel compression
spring. This mechanical action expels the graduated scale rod outward from the base of the sleeve tube,
providing a visible, calibrated pressure reading. The device measures 16.8mm wide by 140mm long.
The pencil tire gauge is made from components sourced from China. The components include the O-ring,
rubber piston, scale rod, scale guide sleeve, pocket clip, PA66 plastic pellets (used to make the air chuck
head) and stainless steel (used to make the spring and outer sleeve).
All of the Chinese components are then sent to Malaysia where the compression spring and outer sleeve are
CNC machined. Additionally, the PA66 plastic is injection molded, chrome plated, and inspected to form the
finished air chuck head. Once the metal and plastic components are made, they are then assembled with the
remaining Chinese components to form the complete pencil tire gauge.
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.
Based upon your description of the manufacturing operations, we note that a significant amount of the core
components that comprise the pressure gauge are manufactured (CNC machined and injection molded) in
Malaysia. Additionally, these components along with the Chinese O-ring, plastic stopper, scale rod, piston,
and pocket clip, emerge with a new name, character, and use, different from those possessed by the raw metal
and plastic material. Thus, based on the totality of the circumstances, the country of origin of the pencil tire
gauge (item number 1121200011) will be Malaysia.
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 Jason Christie at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division