OT:RR:NC:N4:424
Mr. David Rutt
Maersk Customs Services USA Inc.
1501 S. Clinton Street Suite 210
Baltimore, MD 21224
RE: The Country of Origin of titanium and stainless-steel golf club driver heads finished in China
Dear Mr. Rutt:
This is in response to your letter dated February 26, 2025, requesting a country of origin determination on behalf of your client, Cobra Golf Incorporated, of Carlsbad, California. A description of the manufacturing processes of golf club driver heads was submitted for our review.
The merchandise under consideration concerns three models of golf club heads imported by Cobra Golf Inc., which are identified as the “CPG- 001 Driver”, the “CPG-002 Fairway” and the “CPG-003 Hybrid” heads. According to the information you have provided in your request, the manufacturing process for all three golf club heads occurs in Vietnam. You state the titanium driver golf heads, stainless-steel fairway heads, stainless-steel hybrid heads are formed through a series of casting processes in Vietnam using raw titanium or raw stainless-steel sourced from China. The production process for the driver, fairway, and hybrid heads includes treating, melting and casting raw titanium or stainless-steel using wax injection molds. Specifically, the process begins by injecting wax into a tooling or mold to form the shape of the finished golf head. The waxes, carrying the construction and characteristic details of a golf head, are assembled and layered together to create thick, heat-resistant hard-shell clusters. The titanium or stainless-steel material is melted in a high-temperature furnace and is then cast into the de-waxed, pre-heated shell clusters. After the casting is complete, the shell clusters undergo a deshelling process and are broken into individually casted golf heads. Each casted titanium or stainless-steel golf head is further sandblasted and polished into the final size and shape of the corresponding golf head model. The golf heads are then inspected, packed and shipped to China for the final cosmetic finishing operations.
According to your request, the finishing operations in China include face/crown/sole welding or bonding, hosel machining, masking and painting or PVD coating, and decal application resulting in the cosmetically finished golf heads. The finished golf heads are then inspected, packed and exported to the U.S.
With regard to your request for the appropriate country of origin of the aforementioned golf driver heads, 19 C.F.R. § 134.1(b) provides in pertinent part as follows:
Country of origin means 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.” A substantial transformation occurs when articles lose their identity and become articles having a new name, character, or use.
In order to determine whether a substantial transformation occurs when components of various origins are assembled into completed products, all factors such as the components used to create the product and manufacturing processes that these components undergo are considered in order to determine whether a product with a new name, character and use has been produced. No one factor is decisive, and assembly operations that are minimal will generally not result in a substantial transformation.
In this instance, it is this office’s opinion that the manufacturing operations of “CPG- 001 Driver”, the “CPG-002 Fairway” and the “CPG-003 Hybrid” driver heads in Vietnam provide the essence of these articles. The above-mentioned titanium and stainless-steel casting processes from the raw materials to the final shape of the golf head takes place in Vietnam. The finishing processes performed in China give the aesthetics to the casted golf heads, which originated from Vietnam. In our view, these items are not substantially changed by the welding, machining or the cosmetic finishing processes performed in China. Therefore, based on the facts presented in this case, the country of origin of the “CPG- 001 Driver”, the “CPG-002 Fairway” and the “CPG-003 Hybrid” driver heads is Vietnam.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 177).
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 19 CFR 177.9(b)(1). In the event that the facts or merchandise are modified in any way, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and you should resubmit for a new ruling in accordance with 19 CFR 177.2.
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 Roseanne Murphy at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division