N357063

N357063 January 12, 2026 CLA-2-39:OT:RR:NC:N4:415 CATEGORY: Classification; Marking; Country of Origin; Trade Programs TARIFF NO.: 3926.90.9989 Phillippe Porlier Beyond FX 61 Place Berlioz Candiac, QC J5R 3Z5 Canada RE: The classification, marking, country of origin, and United States-Mexico-Canada Trade Agreement (“USMCA”) eligibility of a plastic clamping tool. Dear Mr. Porlier: In your letter dated December 16, 2025, you requested a ruling for the tariff classification, marking, country of origin, and eligibility of a plastic clamping tool under the USMCA. Images were provided in lieu of a sample. The product under consideration is described as the “PCB CLAW” which is a specialized tool designed to securely hold printed circuit boards (“PCBs”) during electronic component assembly and soldering operations. It is made primarily of polyethylene terephthalate glycol-modified (“PETG”) thermoplastic. This tool features a clamping mechanism with adjustable arms that have grooved grip pads designed to hold electronic components firmly in place. It will measure six inches by four inches by four inches. The PCB CLAW is produced through fused deposition modeling (“FDM”) 3D printing technology. The PETG filament is heated and deposited layer-by-layer to create the finished tool. It will be manufactured entirely in Canada. The PETG filament is sourced from Canada, the PETG raw materials are sourced from the United States, and the included six metal fasteners (nuts and bolts) are produced outside of North America. CLASSIFICATION In your request, you proposed classification of this item under heading 8205. As the working surface of this tool is plastic, it would not meet the requirements set forth in Chapter 82, Note 1 and must be classified elsewhere. We agree with your alternative classification within heading 3926. As the “PCB CLAW” would be considered an article of plastic, and as it is not more specifically provided for elsewhere, the applicable subheading will be 3926.90.9989, Harmonized Tariff Schedule of the United States (“HTSUS”), which provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 5.3 percent ad valorem. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. COUNTRY OF ORIGIN 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. Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in sections 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining the country of origin of a good for marking purposes, with the exception of textile and apparel goods which are subject to the provisions of 19 CFR 102.21. See 19 CFR 102.11. Applied in sequential order, 19 CFR 102.11(a) provides that the country of origin of a good is the country in which: (1) The good is wholly obtained or produced; (2) The good is produced exclusively from domestic materials; or (3) Each foreign material incorporated in that good undergoes an applicable change in tariff classification set out in Part 102.20 and satisfies any other applicable requirements of that section, and all other applicable requirements of these rules are satisfied. The “PCB CLAW” is neither “wholly obtained or produced” nor “produced exclusively from domestic materials.” Therefore, paragraphs (a)(1) and (a)(2) cannot be used to determine the country of origin of this article, and paragraph (a)(3) must be applied next to determine the origin of the finished articles. As indicated above, this clamping tool is classified under heading 3926. The tariff shift requirement in part 102.20 for the articles of heading 3926 at issue states, “[a] change to heading 3922 through 3926 from any other subheading, including another heading within that group, except for a change to heading 3926 from articles of apparel and clothing accessories, other articles of plastics, or articles of other materials of headings 3901 to 3914 of heading 9619.” The plastic filament and metal fasteners that make up the PCB holding tool are classified outside of heading 3926 and would meet the required tariff shift, and therefore, in accordance with 19 CFR § 102.11(a)(3), the country of origin of the “PCB CLAW” is Canada. MARKING Section 304 of the Tariff Act of 1930, as amended (19 USC 1304), provides that unless excepted, every article of foreign origin (or its container) 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 USC 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. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). As the country of origin for this product is Canada, it must be marked “Made in Canada” in accordance with the applicable statute and regulations. USMCA The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act. General Note (“GN”) 11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states, in relevant part: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a “good originating in the territory of a USMCA country” only if – (i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; (ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; (iii) the good is a good produced entirely in the territory of one or more USMCA countries using non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o)); Since the six metal fasteners (nuts and bolts) are non-originating, the subject merchandise is not considered a good wholly obtained or produced entirely in a USMCA country under GN 11(b)(i), nor is the product exclusively from originating materials per GN 11(b)(ii). Thus, we must determine whether the product qualifies under GN 11(b)(iii). As previously noted, the plastic clamping tool is classified under subheading 3926.90.99, HTSUS. The applicable rule of origin for merchandise classified under

tool are classified outside of heading 3926 and would meet the required tariff shift, and therefore, in accordance with 19 CFR § 102.11(a)(3), the country of origin of the “PCB CLAW” is Canada. MARKING Section 304 of the Tariff Act of 1930, as amended (19 USC 1304), provides that unless excepted, every article of foreign origin (or its container) 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 USC 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. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). As the country of origin for this product is Canada, it must be marked “Made in Canada” in accordance with the applicable statute and regulations. USMCA The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act. General Note (“GN”) 11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states, in relevant part: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subhea