N348221

N348221 May 12, 2025 OT:RR:NC:N1:103 CATEGORY: Origin Helen Xiao Ernst & Young LLP 155 N Wacker Dr., #2000 Chicago, IL 60606 RE: The country of origin of a jack stand and engine stand Dear Ms. Xiao: In your letter dated April 24, 2025, you requested a country of origin ruling on behalf of your client, Torin (Thailand) Co., Ltd. The first item under consideration is described as a height-adjustable jack stand (Item THJ3-2) which supports the weight of a vehicle during or after lifting by another device. Primarily composed of iron and steel, the subject jack stand contains six main components: a ratchet bar, a base, a locking pawl, a locking handle, a handle sleeve, and a spring pin. During use, the user adjusts the height of the jack stand’s ratchet bar to a desired height to meet the chassis of a raised vehicle. Once the desired height is reached, teeth on the iron ratchet bar engage with a locking pawl within the steel base to prevent the ratchet bar from falling. As a result, the extended ratchet bar remains in position and the jack stand can bear the weight of a raised vehicle. In your letter, you assert that the jack stand is fully manufactured in Thailand using raw materials from China and Thailand. Specifically, steel sheet, steel bar, springs, and handle covers from China are imported into Thailand. In addition, scrap iron and packing materials from Thailand are incorporated into the final product. Manufacturing of the ratchet bar begins with scrap iron casting to shape and size. After the iron casting undergoes cooling and solidification, sand is removed, and it undergoes shot blasting to remove additional sand, burrs, and oxide scale. At that point, the ratchet is electrostatically powder coated to provide a durable, corrosion-resistant coating. The jack stand base manufacturing and assembly begins with the stamping of Chinese steel sheets using stamping dies and a stamping machine to form the parts of the upper reinforcement, lower reinforcement, collar, and base. The formed parts are then bent in the stamping machine using forming dies. Following that, various component parts of the jack stand base are welded together at a robotic welding station. After welding, the slag is cleaned and the welds are inspected. The locking pawl manufacturing begins with scrap iron casting to shape and size, shot blasting, and drilling to create a large hole to specification. The locking handle manufacturing begins with the cutting of round steel bars from China to length using a sawing machine. The cut steel sections are formed into the desired shape in a stamping machine and holes are drilled using a drilling machine. Final assembly begins with the insertion and securing of the locking handle and pawls into the base collar. The assembled jack stand is tested on a loading machine to check its strength before shot blasting, powder coating and packing for shipment. When determining the country of origin for purposes of applying current trade remedies under Section 301, and any 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). Based on your described scenario and the submitted information, it is the opinion of this office that the raw, unfinished iron and steel materials from China and Thailand undergo a substantial transformation in Thailand. Before processing in Thailand, the raw materials do not possess the physical characteristics necessary for use as a jack stand. After the manufacturing operations and assembly with less-significant Chinese components in Thailand, the components lose their individual identities and a different article emerges with a new name, character, and use. Accordingly, the country of origin of the jack stand is Thailand. The second item under consideration is identified as an engine stand (Item THE0.45-1E) and is described as a weight supporting tool used to support engines during repairs or assembly work. It has a 360-degree rotating engine mount and a heavy-duty steel post that is supported by a fixed base with wheels. The engine stand is composed of eighteen discrete components that are imported unassembled in retail packaging. The end user is responsible for final assembly. The main components, including a head assembly, a handle assembly, and the structural components, are produced in Thailand. The structural components form the body of the stand, and are identified as a main post, rear support, crossbeam, and front leg. The main post is created from five intermediate metal forms referred to as a positioning tube, a square tube, a steel angle, a reinforcing rib, and a pillar. These subcomponents are created in Thailand from material lengths of round steel tubing, square steel tubing, steel bar, or rectangular tubing that are first cut to length then moved to a punch press where a worker creates holes or other shaped openings. Afterwards, the pieces are aligned and welded together to create a unified assembly. The main post will sit atop an I-shaped base, which consists of a central crossbeam, a rear support, and a front leg. These components are shipped unassembled and created using similar operational steps, beginning with cutting material lengths of square steel tubing, angle steel bar, or round steel bar into the required length. The cut pieces are moved to machines that punch or drill holes, then forwarded to robotic welding stations where additional pieces, such as shafts or base plates, are joined. The head assembly is used to secure an engine to the stand and will be mounted on top of the main post. It is created from welding a positioning tube to a mounting plate. Both the positioning tube and mounting plate are created in Thailand and will contain openings that allow the head assembly to rotate and hold an engine in different positions. The head assembly will also have mounting arms created from a steel square bar that is cut to length, drilled, and welded to steel tubing. The handle assembly is a lever used by the operator to manipulate the engine and is described as a cut-to-length round steel tube that has been shot blasted and powder coated in Thailand. The main post, rear support, crossbeam, front leg, head assembly, and handle assembly are packaged together with miscellaneous finished components sourced from China. These include a caster assembly, a handle sleeve, and various fasteners, including lock pins, washers, nuts, and bolts. Based upon your description of the manufacturing operations, we note the dominant components, including the head assembly, handle assembly, and all structural components are manufactured in Thailand. These components are critical parts of an engine stand, and emerge from the process with a new name, character, and use, different from that possessed by the materials (e.g., round steel tubing, square steel tubing, steel bar, steel sheets, or rectangular tubing) prior to the processing. Thus, based on the totality of the circumstances, the country of origin of the engine stand will be Thailand. 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 

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). Based on your described scenario and the submitted information, it is the opinion of this office that the raw, unfinished iron and steel materials from China and Thailand undergo a substantial transformation in Thailand. Before processing in Thailand, the raw materials do not possess the physical characteristics necessary for use as a jack stand. After the manufacturing operations and assembly with less-significant Chinese components in Thailand, the components lose their individual identities and a different article emerges with a new name, character, and use. Accordingly, the country of origin of the jack stand is Thailand. The second item under consideration is identified as an engine stand (Item THE0.45-1E) and is described as a weight supporting tool used to support engines during repairs or assembly work. It has a 360-degree rotating engine mount and a heavy-duty steel post that is supported by a fixed base with wheels. The engine stand is composed of eighteen discrete components that are imported unassembled in retail packaging. The end user is responsible for final assembly. The main components, including a head assembly, a handle assembly, and the structural components, are produced in Thailand. The structural components form the body of the stand, and are identified as a main post, rear support, crossbeam, and front leg. The main post is created from five intermediate metal forms referred to as a positioning tube, a s