N365097

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365097 October 8, 2026 OT:RR:NC:N5:116 CATEGORY: Origin; Marking Shanshan Liang Liang + Mooney, PLLC 2104 Delta Way, Unit 1 Tallahassee, FL 32303 RE: The country of origin of marking of alloy steel oil country tubular goods and nonalloy steel couplings Dear Ms. Liang: In your letter dated September 16, 2026, you requested a country of origin ruling and a marking ruling on alloy steel oil country tubular goods (“OCTGs”) and 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 alloy steel OCTGs and 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 three different scenarios: 1) OCTGs, specifically electric resistance welded (“ERW”) steel casing and tubing, imported without couplings, 2) API 5CT couplings imported separately, and 3) OCTGs imported with preassembled couplings. In the first scenario, alloy steel coils of Chinese, South Korean, or Malaysian origin are sent to Cambodia where they are slit, straightened, leveled, and 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, API 5CT steel couplings are manufactured in Cambodia from unfinished nonalloy steel pipe (coupling stock) of Chinese origin. In Cambodia, long lengths of seamless steel pipe are cut to short lengths, internally and externally turned, beveled, threaded, phosphate coated, marked, painted, packaged, and then shipped to the U.S. You state that the coupling stock is manufactured into finished API 5CT couplings as a result of the extensive machining, inspection, testing, and finishing operations performed in Cambodia. The couplings are used to connect lengths of casing and tubing. In the third scenario, alloy 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 Chinese origin coupling stock 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 alloy steel coils and nonalloy steel API 5CT couplings have been substantially transformed in Cambodia. 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 alloy 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 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 th

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 count