CBP Says Golf Club Importers Must Report Origin of Each Component
Golf clubs are commonly made with components from multiple countries of origin and may be subject to additional tariffs, depending on the origin, CBP said in a May 18 CSMS message. That is why importers of completed golf clubs are required to include origin information for each component, it said.
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"If either the head or the shaft is of the same origin as the country where the assembly of the golf club occurs, the country of origin of the entire club is the country of its assembly," CBP said. "Where the origin of both the head and the shaft is different from the country of assembly of the golf club, the golf club will have multiple countries of origin, including the countries of origin of the head and the shaft."
The golf club components "may be manufactured in multiple countries and are subject to Section 301 duties if the country of origin is China," CBP said. The agency cited two recent CBP rulings, one from December 2020 (see 2012110048) that said the shaft of a club assembled in Mexico is subject to Section 301 tariffs on goods from China, and another from October 2020 about the country of origin of the same clubs.
CBP also explained the entry process for complete clubs, which are classified in subheading 9506.31.00, with multiple countries of origin. "In order to properly report the applicable trade remedies on each golf club component, filers are required to break out each component of the golf club by the country of origin," the agency said. "Each entry/entry summary line should use the same tariff classification as the classification for the completed golf club. When reporting components on separate entry/entry summary lines, filers should use the actual value of the component."
The CSMS message also included a spreadsheet with examples of the correct entry summary reporting. "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 filer reports the golf club on one line with one country of origin," CBP said. But, "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, the filer reports the golf club on multiple lines. This will allow reporting of the correct country or countries of origin, value and any applicable Section 301 duties."
CBP previously offered a guidance on pipe spools that had multiple countries of origin, similarly asking for a breakout of component origin upon entry so it could assess any Section 301, Section 232 or antidumping or countervailing duties that may apply. The National Customs Brokers & Forwarders Association of America said at the time it was concerned about the CBP approach (see 2004220021).