Cargo Systems Messaging Service

CSMS #47830638 - Guidance: Proper Entry/Entry Summary Reporting for Complete Golf Clubs with Components from Multiple Countries of Origin

Complete golf clubs are made of prefabricated components consisting of a head, shaft, and grip. These components may be manufactured in multiple countries and are subject to Section 301 duties if the country of origin is China. 

It is not uncommon for a golf club to be manufactured with components from multiple countries.  The country of assembly is an important factor in determining the country of origin of the golf clubs.  While the entire golf club has one tariff classification, the country of origin of the components of the golf club may need to be indicated. (See HQ H313495, dated December 2, 2020; and HQ H313537, dated October 16, 2020).

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. 

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.

This memorandum provides guidance on proper entry/entry summary line reporting in the Automated Commercial Environment (ACE) for trade remedies and other requirements.

GUIDANCE

Complete golf clubs are classified under subheading 9506.31.00 of the Harmonized Tariff Schedule of the United States (HTSUS).  Where a golf club has 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.  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.

For example, 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.  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, 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.

In compliance with CBP invoice requirements, the commercial invoice must include a detailed description of the merchandise, materials, value, quantity, HTSUS, and country or countries of origin (See 19 C.F.R. § 141 Subpart F for full requirements). The invoice and supporting documents must provide sufficient information to determine the value, quantity, HTSUS and country or countries of origin of the components of the completed golf club.

The attached spreadsheet provides examples of the correct entry summary reporting for complete golf clubs.

If you have policy questions, please contact the Trade Remedy Branch at traderemedy@cbp.dhs.gov.