A recent guidance document from U.S. Customs and Border Protection on the country of origin of golf clubs made with prefabricated components is raising some concerns about whether CBP might take a similar approach with other composite articles.
According to CBP, complete golf clubs are classified under HTSUS 9506.31.00. If all the components have the same country of origin, or if either the head or the shaft is of the same origin as the country where the golf club is assembled, the country of origin of the entire club is the country of its assembly and the filer reports the club on one line with one country of origin.
However, if the golf club has components from two or more countries of origin and the origin of both the head and the shaft is other than the country where the golf club is assembled, filers must break out each component by country of origin. Each entry/entry summary line should use the same tariff classification as the completed golf club. When reporting components on separate lines, filers should use the actual value of the component.
CBP states that this method will allow reporting of the correct country or countries of origin, value, and any applicable Section 301 duties, which will be applied to the value of any Chinese-origin component (e.g., head, shaft, grip) included within the finished club.
CBP adds that the commercial invoice must include a detailed description of the merchandise, materials, value, quantity, HTSUS number, and country or countries of origin, and that the invoice and supporting documents must provide sufficient information to determine the value, quantity, classification, and country or countries of origin of the components of the completed golf club.
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