Country of Origin; USMCA Eligibility; Applicability of Subheadings 9802.00.40, or 9802.00.80, HTSUS; Semi-Vulcanized Rubber Hoses

H351116 April 16, 2026 OT:RR:CTF:VS H351116 MAT CATEGORY: Origin Ms. Kimberly Tracy OESL Automotive USA, LLC 2044 Austin Ave Rochester Hills, MI 48309 RE: Country of Origin; USMCA Eligibility; Applicability of Subheadings 9802.00.40, or 9802.00.80, HTSUS; Semi-Vulcanized Rubber Hoses Dear Ms. Tracy: This is in response to your ruling request dated July 18, 2025, filed on behalf of OESL Automotive USA, LLC (“Importer”), concerning the eligibility of certain semi-vulcanized rubber hoses for preferential tariff treatment under the United States-Mexico-Canada Agreement (“USMCA”), applicability for subheadings 9802.00.40, Harmonized Tariff Schedule of the United States (“HTSUS”), or 9802.00.80, HTSUS, treatment, and country of origin for marking purposes. FACTS: The Importer plans to manufacture the subject rubber hoses in the United States, export them to Mexico for further processing, and then re-import them into the United States for use as original parts in passenger vehicles and light trucks in the automotive industry. The manufacturing of the finished goods will be a three-step process. Step 1: Initial Manufacturing In the United States, the semi-vulcanization process for the rubber hoses begins with compounding, a multi-stage extrusion and reinforcement process. You assert that, first, U.S. originating chloroprene, classifiable in subheading 4009.11.00,1 HTSUS, is extruded to form the core. Then, a layer of U.S. originating nylon 6/66, classifiable in subheading 3908.10.00,2 1 Subheading 4009.11.00, HTSUS, provides for: “Tubes, pipes and hoses, of vulcanized rubber other than hard rubber, with or without their fittings (for example, joints, elbows, flanges): Not reinforced or otherwise combined with other materials: Without fittings.” 2 Subheading 3908.10.00, HTSUS, provides for: “Polyamides in primary forms: Polyamide-6, -11, -12, -6,6, -6,9, - 6,10 or -6,12.” HTSUS, is applied over the tube. Additional U.S. originating chloroprene is applied as a friction layer to promote adhesion between the layers. Next, the hose is reinforced with originating Aldora PET yarn classifiable in subheading 5604.90.20,3 Chinese HTSUS, which is imported in its raw form, twisted, treated with an isocyanate dip, and wound on spools for braiding. Lastly, an additional cover of U.S. originating chloroprene and butyl is extruded over the braided layer. During the first stage, partial vulcanization is performed, where controlled heat and pressure are applied to partially cross-link the rubber’s polymer chains. This results in a semi- vulcanized hose, which is stable, pliable, and not yet fully cured. The initial manufacturing sufficiently cures the hoses to preserve their structural integrity upon mandrel removal. The resulting partially cured hoses are then exported to Mexico to complete the curing process and shape the hoses into their final, desired form. Although the semi-vulcanized hoses are only partially cured and not functional in their form at this stage, they are classified in subheading 4009.31.00,4 HTSUS. Step 2: Final Processing In Mexico, the final stage of the vulcanization process includes fully curing the semi- vulcanized rubber hoses by subjecting them to heat and pressure in an autoclave or oven, which cross-links the rubber to achieve its ultimate material properties including enhanced elasticity, tensile strength, and resistance to environmental factors. In addition, the hoses undergo forming, which involves shaping them into specific configurations (e.g., curves and precise dimensions from mandrels or molds) during or immediately following the final vulcanization, in conjunction with additional heat to stabilize the structure. Lastly, the semi-vulcanized rubber hoses are cut to specified lengths. You assert that the finished semi-vulcanized rubber hoses are classifiable in subheading 4009.31.00, HTSUS. Step 3: Re-importation into the United States The fully cured, semi-vulcanized rubber hoses are imported back into the United States and are intended for use as original parts in passenger vehicles and light trucks in the automotive industry. 3 Subheading 5604.90.20, HTSUS, provides for: “Rubber thread and cord, textile covered; textile yarn, and strip and the like of heading 5404 or 5405, impregnated, coated, covered or sheathed with rubber or plastics: Other: High tenacity yarn of polyesters, of nylon or other polyamides or of viscose rayon, impregnated or coated (201).” 4 Subheading 4009.31.00, HTSUS, provides for: “Tubes, pipes and hoses, of vulcanized rubber other than hard rubber, with or without their fittings (for example, joints, elbows, flanges): Reinforced or otherwise combined only with textile materials: Without fittings.” 2 ISSUES: 1. Whether the semi-vulcanized rubber hoses are eligible for preferential tariff treatment under the USMCA. 2. Whether the semi-vulcanized rubber hoses qualify for subheadings 9802.00.40, HTSUS, or 9802.00.80, HTSUS, treatment. 3. Whether the semi-vulcanized rubber hoses are of U.S. or Mexican origin for country of origin marking purposes under 19 C.F.R. Part 102. LAW AND ANALYSIS: 1. Eligibility for Preferential Tariff Treatment under the USMCA The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note (“GN”) 11, HTSUS, implements the USMCA and sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11, HTSUS, states, in relevant part: (a) Goods originating in the territory of a country named herein, pursuant to the United States-Mexico-Canada Agreement (USMCA), are subject to duty as provided herein, including any treatment set forth in subchapter XXIII of chapter 98 and subchapter XXII of chapter 99 of the tariff schedule. For the purposes of this note, as provided in the tariff schedule – (i) Goods that originate in the territory of Mexico, Canada or the United States (hereinafter referred to as “USMCA country” or “USMCA countries” as further defined in subdivision (l)(xxiv) of this note) under the terms of subdivision (b) of this note and regulations issued by the Secretary of the Treasury (including Uniform Regulations provided for in the USMCA), and goods enumerated in subdivision (p) of this note, when such goods are imported into the customs territory of the United States and are entered under a subheading for which a rate of duty appears in the “Special” subcolumn, followed by the symbol “S” in parentheses, are eligible for such duty rate, in accordance with section 202 of the United States-Mexico-Canada Agreement Implementation Act; … (b) For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country … is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a “good originating in the territory of a USMCA country” only if – 3 (i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; (ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; (iii) the good is a good produced entirely in the territory of one or more USMCA countries using nonoriginating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o)); … Here, the goods do not qualify as wholly obtained or produced under GN 11(b)(i) or produced exclusively from originating materials under GN 11(b)(ii). We must therefore consider whether the merchandise qualifies as originating under GN 11(b)(iii). As noted above, the merchandise is classified in subheading 4009.31.00, HTSUS. The applicable product-specific rule of origin in GN 11(o)/40.9 is underscored and requires: 9. A change to subheading 4009.31 from any other heading, except from headings 4010 through 4017. The subheading rule for goods of 4009.31, HTSUS, provides that, “[t]he underscoring of the designations in subdivision 9 pertain to goods provided in subheading 4009.31 for use in a motor vehicle of chapter 87.” Furthermore, Chapter rule 1 for goods of Chapter 40 provides that “[f]or the purposes of the subdivisions pertaining to this chapter, whenever the subdivision designation is underscored, the provisions of subdivision (k) of this note may apply to goods for use in a motor vehicle of chapter 87.” Here, because the product-specific rule is underscored and the merchandise is for use in a motor vehicle of chapter 87 (namely, a passenger vehicle or light truck), the provisions of subdivision (k) may apply. GN 11(k) provides special rules for automotive goods. GN 11(k)(i) states: An automotive good and other motor vehicles and parts described herein shall be subject to applicable requirements set forth in this paragraph, including, with respect to a passenger vehicle or light truck that has been authorized to use the alternative staging regime described under subparagraph (viii), applicable requirements for the duration of the alternative staging period specified in the approval. GN 11(k)(ii)(E)(2) includes in the definition of an “automotive good” any “part, component or material listed in table A.1, A.2, B, C, D, or E of the automotive appendix, subject to any provisions that may be included in regulations issued by the Secretary of the Treasury.” GN 11(k)(ii)(D) defines “automotive appendix” as “. . . the Appendix to Annex 4-B of the USMCA (relating to the product-specific rules of origin for automotive goods, as reflected in subdivision (o) of this note).” 4 Examining Table C of the automotive appendix “Complementary Parts for Passenger Vehicles and Light Trucks,” the following goods of heading 4009 are listed: • 4009.12 – Tubes, pipes and hoses of vulcanised rubber other than hard rubber, not reinforced or otherwise combined with other materials, with fittings. • 4009.22 – Tubes, pipes and hoses of vulcanised rubber other than hard rubber, reinforced or otherwise combined only with metal, with fittings. • 4009.32 – Tubes, pipes and hoses of vulcanised rubber other than hard rubber, reinforced or otherwise combined only with textile materials, with fittings. • 4009.42 – Tubes, pipes and hoses of vulcanised rubber other than hard rubber, reinforced or otherwise combined with other materials, with fittings. Here, however, the subject semi-vulcanized rubber hoses are classified in 4009.31, HTSUS, and unlike the goods listed above, do not contain fittings. Further, while heading 4009 is listed in Table F, it is indicated that the hoses at issue are for use in passenger vehicles and/or light trucks, and not for use in other vehicles set forth in article 10 of the automotive appendix. Accordingly, pursuant to GN 11(k)(ii)(E)(2), the subject merchandise is not an “automotive good” to which the USMCA automotive provisions apply, and whether the goods qualify as originating will be determined under the applicable product-specific rule of origin in GN 11(o)/40.9. When determining whether the rule of origin is satisfied, GN 11(d)(i) provides that “[a] good that is produced in the territory of one or more USMCA countries, by one or more producers, is an originating good if the good satisfies the requirements of subdivision (b) of this note and all other applicable requirements.” Therefore, when determining whether the finished goods qualify as originating when imported into the United States from Mexico, both the U.S. and Mexican production may be taken into account. In this case, the sole non-originating material used in the production of the semi- vulcanized rubber hoses in the United States and Mexico is the Chinese Aldora PET yarn of 5604.90, HTSUS. During the initial manufacturing process, the Chinese Aldora PET yarn undergoes the required tariff shift from 5604.90, HTSUS, to become semi-vulcanized rubber hoses of 4009.31, HTSUS. As such, the finished product will qualify as USMCA originating when imported into the United States from Mexico. 2. Applicability of Subheadings 9802.00.40 or 9802.00.80, HTSUS a. Subheading 9802.00.40, HTSUS, and Subheading 9802.00.50, HTSUS Subheading 9802.00.40, HTSUS, provides a full or partial duty exemption for articles returned to the United States after having been exported to be advanced in value or improved in condition by means of a repair or alteration, when such repair or alteration is made pursuant to a warranty. Subheading 9802.00.50, HTSUS, provides the same duty exemption for articles exported for repairs or alterations made other than pursuant to a warranty. Such articles are 5 dutiable only upon the cost or value of the foreign repairs or alterations, provided that the requirements of 19 C.F.R. § 182.112 are met. However, the application of these tariff provisions is precluded in circumstances where the operations performed abroad destroy the identity of the articles or create new or commercially different articles. See A.F. Burstrom v. United States, 44 CCPA 27, C.A.D. 631 (1957); see also Guardian Industries Corporation v. United States, 3 CIT 9, Slip-Op 82-4 (Jan. 5, 1982). Treatment under subheadings 9802.00.40, HTSUS, and 9802.00.50, HTSUS, is also precluded where the exported articles are incomplete for their intended use and the foreign processing operation is a necessary step in the preparation or manufacture of the finished articles. See Dolliff & Company, Inc. v. United States, 66 CCPA 77, C.A.D 1225, 599 F.2d 1015 (1979) (“repairs and alterations are made to completed articles and do not include intermediate processing operations which are performed as a matter of course in the preparation or the manufacture of finished articles”). Thus, the focus is upon whether the exported article is “incomplete” or “unsuitable for its intended use” prior to the foreign processing. See also Guardian Industries Corp. v. United States, 3 CIT 9 (1982) (finding that the tempering of glass is not an alteration but part of the manufacturing process because the glass was unsuitable for its intended use before tempering). In Headquarters Ruling (“HQ”) 557659, dated January 27, 1994, CBP considered whether foreign air brushing and hot wire cutting of U.S. originating curtain fabric to highlight the decorative motifs in the patterns and enhance the design of the fabric constituted an alteration under subheading 9802.00.50, HTSUS. CBP found that these foreign processes constituted acceptable alterations considering “the fabric in its exported condition [was] marketed as fabric for curtains and [was] marketed for the same use after the air brushing and hot-wire cutting operations, [which] show that the fabric [was] suitable for its intended use, and that it [was] exported in its completed condition.” Conversely, in HQ 555085, dated September 27, 1988, CBP determined that foreign cutting (to size and shape) and polishing of glass sheets constituted operations which exceeded repairs or alterations. CBP focused on the fact that “the glass was cut to size and shape, ground and polished, which [were] all necessary steps in the preparation of the finished window portions of small machines.” As such, seeing the glass sheets were not finished articles complete nor suitable for their intended use, the cutting and polishing did not constitute acceptable repairs or alterations under subheading 9802.00.50, HTSUS. In the present case, no evidence was provided to CBP as to the existence of repairs or alterations of the semi-vulcanized rubber hoses nor any indication that a warranty on the merchandise is at issue here. Without a warranty at issue, subheading 9802.00.40, HTSUS, is not the appropriate provision for the semi-vulcanized rubber hoses upon re-importation into the United States. 6 Turning towards subheading 9802.00.50, HTSUS, the semi-vulcanized rubber hoses, like the glass sheets in HQ 555085, are incomplete and unsuitable articles for their intended use at the time of exportation to Mexico. After the first stage of manufacturing in the United States, the hoses contain partially cross-linked rubber polymer chains which results in a stable, pliable, but not yet fully cured hose. The hoses are cured only enough to preserve their structural integrity for mandrel removal. As stated by the Importer, once the hoses are exported to Mexico, the second step of processing includes “fully curing, shaping, and cutting the hoses [as] necessary components of the manufacturing process of the finished articles.” In line with the reasoning in Dolliff, the curing, shaping, and cutting processes in Mexico constitute processes of manufacture (as described in the information furnished to CBP) and clearly exceed the meaning of the terms “repairs or alterations” under subheading 9802.00.50, HTSUS, again, the applicable provision here considering a warranty is not involved. Therefore, the semi-vulcanized rubber hoses would not be entitled to treatment under subheadings 9802.00.40, HTSUS, nor 9802.00.50, HTSUS. b. Subheading 9802.00.80, HTSUS Subheading 9802.00.80, HTSUS, provides a partial duty exemption for: [a]rticles assembled abroad in whole or in part of fabricated components, the product of the United States, which (a) were exported in condition ready for assembly without further fabrication, (b) have not lost their physical identity in such articles by change in form, shape, or otherwise, and (c) have not been advanced in value or improved in condition abroad except by being assembled and except by operations incidental to the assembly process, such as cleaning, lubrication, and painting. All three requirements of subheading 9802.00.80, HTSUS, must be satisfied before a component may receive a duty allowance. An article entered under this tariff provision is subject to duty upon the full cost or value of the imported assembled article, less the cost or value of the U.S. components assembled therein, provided the documentary requirements are met pursuant to 19 C.F.R. § 10.24. 19 C.F.R. § 10.16(a) provides that the assembly operations performed abroad may consist of any method used to join or fit together solid components, such as gluing, laminating, welding soldering, riveting, force fitting, sewing, or the use of fasteners. In addition, operations incidental to the assembly process are not considered further fabrication operations, as they are of a minor nature and cannot always be provided for in advance of the assembly operations. Examples of operations which are incidental to the assembly process include trimming, filing, or cutting off of small amounts of excess materials. See 19 C.F.R. § 10.16(b). However, any significant process, operation or treatment whose primary purpose is the fabrication, completion, physical or chemical improvement of a component precludes the application of the exemption under subheading 9802.00.80, HTSUS, to that component. 19 C.F.R. § 10.16(c). 7 In HQ 560766, dated April 17, 1998, CBP assessed whether joining layers of fabric by applying a rubber adhesive between each layer and subjecting the materials to a vulcanization and curing process constituted acceptable assembly operations. Similarly, CBP evaluated whether the lamination of fabric by applying a molten rubber adhesive to three or four layers and passing the materials through an oven for vulcanization was an “assembly”, in HQ 555361, dated August 3, 1989. In both cases, CBP determined that the materials underwent vulcanization and curing processes which adhered solids together, and while the processes resulted in chemical changes to the rubber components, they did not result in the intermixing of the materials nor a physical change in identity (e.g., form, shape, or otherwise) to the main components, the fabrics. Therefore, the adhesion of the fabrics through curing were appropriate assemblies of solids pursuant to subheading 9802.00.80, HTSUS. See also C.J. Tower & Sons of Buffalo, Inc. v. United States, 62 Cust. Ct. 643, C.D. 3840, 304 F. Supp. 1187 (1969) (finding that the adhesion of two types of plastic – one being a molten liquid – to form a single plastic film was an assembly operation since there was no intermixing of the sheets and the adhesive did not produce a change in the solid plastic’s physical identity, form, or shape). In contrast, in HQ 556422, dated March 24, 1992, CBP held that bending aluminum tubes to specific configurations went beyond mere adjustment of the tubes in the process of assembly and created the final configuration, which is the essence of the tubing. Thus, “the change in shape of the aluminum tube [was] a significant process and [could not] be considered an operation incidental to assembly,” and no allowance in duty was made for the cost or value of the aluminum tubing. However, CBP made an allowance in duty for the cost or value of the U.S. rubber hoses which were cut to length and attached to the aluminum tubing after finding that cutting the rubber hoses to specific lengths was an operation incidental to the assembly process pursuant to 19 C.F.R. § 10.16(b)(6). See also HQ 557178, dated July 1, 1993, where cutting a flexible neoprene hose to lengths of 10 feet was considered an acceptable operation incidental to assembly. The semi-vulcanized rubber hoses in the case at hand are discernible from the layers of fabric adhered by rubber compounds and vulcanized in HQ 560766 and HQ 555361. The semi- vulcanized rubber hoses undergo the second step of processing after exportation to Mexico which includes “fully curing, shaping, and cutting the hoses [as] necessary components of the manufacturing process of the finished articles.” Unlike the curing and assembly of the layers of fabric and rubber in HQ 560766 and HQ 555361, the curing of the semi-vulcanized rubber hoses involves subjecting them to heat and pressure in an autoclave or oven, which cross-links the rubber to achieve the ultimate material properties including enhanced elasticity, tensile strength, and resistance to environmental factors. These processes extend far beyond a simple “assembly” of the materials. In addition, the semi-vulcanized rubber hoses undergo forming, which, like bending the aluminum tubes in HQ 556422, involves shaping the hoses into specific configurations (e.g., curves and precise dimensions from mandrels or molds) during or immediately following the final vulcanization, in conjunction with additional heat to stabilize the structure. Therefore, the curing and forming processes result in further fabrication and a change in the physical identity of the hoses in both form and shape. Accordingly, the curing and shaping processes of the semi- 8 vulcanized rubber hoses are not “assembly operations” nor “operations incidental to the assembly process” and preclude treatment under subheading 9802.00.80, HTSUS. 3. Country of Origin Marking The marking statute, Section 304, Tariff Act of 1930, as amended (19 U.S.C. § 1304), provides that, unless excepted, every article of foreign origin (or its container) 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 markings on the imported goods the country of which the good is the product. “The evident purpose is to mark the goods so 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.” United States v. Friedlaender & Co., 27 C.C.P.A. 297 at 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 C.F.R. Part 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. § 1304. Section 134.1(b) defines “country of origin” as “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’ within the meaning of [the marking laws and regulations].” Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in §§ 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to goods imported from Canada and Mexico. Section 102.11 provides a hierarchy for determining the country of origin of a good for marking purposes. See 19 C.F.R. § 102.11(a). Since the goods will be imported from Mexico, section 102 will govern the determination of whether the goods are products of Mexico. Section 102.11(a) provides a hierarchy for determining the country of origin of a good for marking purposes. Applied in sequential order, the hierarchy establishes the country of origin of a good is the country in which: (1) The good is wholly obtained or produced; (2) The good is produced exclusively from domestic materials; or (3) Each foreign material incorporated in that good undergoes an applicable change in tariff classification set out in § 102.20 and satisfies any other applicable requirements of that section, and all other applicable requirements of these rules are satisfied. 9 “Material” means “a good that is incorporated into another good as a result of production with respect to that other good, and includes parts, ingredients, subassemblies, and components.” 19 C.F.R. § 102.1(l). “Foreign material” is defined in Section 102.1(e) as “a material whose country of origin as determined under these rules is not the same country as the country in which the good is produced.” Here, the subject semi-vulcanized rubber hoses are made from the partially cured hoses and are therefore neither “wholly obtained or produced” nor “produced exclusively from domestic materials.” Thus, paragraphs (a)(1) and (a)(2) cannot be used to determine their country of origin, and we must apply paragraph (a)(3). The tariff shift requirement in 19 C.F.R. § 102.20 for goods of heading 4009, HTSUS, which applies to the rubber hoses at issue, states: A change to heading 4006 through 4010 from any other heading, including another heading within that group. As mentioned above, the semi-vulcanized rubber hoses are exported from the United States to Mexico to be fully cured via heat and pressure treatment, formed to specific configurations, and then cut to certain finished lengths. The cured, formed, and cut semi- vulcanized rubber hoses are then re-imported back into the United States from Mexico. Prior to the heat and pressure treatment and finishing operations in Mexico, the subject merchandise is classified under heading 4009, HTSUS. Following the heat and pressure treatment and finishing operations in Mexico, the subject merchandise remains classified under heading 4009, HTSUS. As the semi-vulcanized rubber hoses do not undergo a change in tariff classification, the rule set forth in 19 C.F.R. § 102.20 is not met. As the country of origin of the semi-vulcanized rubber hoses cannot be determined pursuant to 19 C.F.R. § 102.11(a), we turn to 19 C.F.R. § 102.11(b). Section 102.11(b)(1) provides, in pertinent part, that “where the country of origin cannot be determined under paragraph (a) of the section, the country of origin of the good is the country or countries of origin of the single material that imparts the essential character to the good.” Section 102.18(b)(1) provides that “for purposes of identifying the material that imparts the essential character to a good under § 102.11, the only materials that shall be taken into consideration are those domestic or foreign materials that are classified in a tariff provision from which a change in tariff classification is not allowed under the § 102.20 specific rule or other requirements applicable to the good.” Here, the single material is the partially cured semi-vulcanized hose of subheading 4009.31.00, HTSUS. Therefore, the country of origin of the finished hose will be the country of origin of the partially cured hose. The partially cured hose is produced in the United States and is composed of U.S. originating chloroprene, nylon 6/66, and butyl as well as Chinese Aldora PET yarn. As the partially cured hose meets the requisite tariff shift in the United States, the partially cured hose is considered a product of the United States, and pursuant to 19 C.F.R. § 10 102.11(b), the country of origin of the finished hose is the United States.5 Please note that if you wish to mark the goods or the packaging to indicate that they are “Made in the USA,” the marking must comply with the requirements of the Federal Trade Commission (“FTC”). We suggest that you direct any questions on this issue to the FTC. HOLDING: The semi-vulcanized rubber hoses are USMCA originating and may qualify for preferential tariff treatment when imported into the United States from Mexico. The semi-vulcanized rubber hoses are not entitled to treatment pursuant to subheadings 9802.00.50, HTSUS, or 9802.00.80, HTSUS. Pursuant to 19 C.F.R. § 102.11(b)(1), the country of origin of the semi-vulcanized rubber hoses is the United States. Please note that 19 C.F.R. § 177.9(b)(1) provides that “[e]ach ruling letter is issued on the assumption that all of the information furnished in connection with the ruling request and incorporated in the ruling letter, either directly, by reference, or by implication, is accurate and complete in every material respect. The application of a ruling letter by a [CBP] field office to the transaction to which it is purported to relate is subject to the verification of the facts incorporated in the ruling letter, a comparison of the transaction described therein to the actual transaction, and the satisfaction of any conditions on which the ruling was based.” A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is entered. If the documents have been filed without a copy, this ruling should be brought to the attention of the CBP officer handling the transaction. Sincerely, Monika R. Brenner Chief, Valuation & Special Programs Branch 5 We also note that, under the substantial transformation standard, the processing in Mexico does not result in a change in name, character, or use. Based on the information provided, the last substantial transformation occurs in the United States, where the partially cured hose is produced, as this material imparts the essence to the final product. Therefore, under this standard, the country of origin of the good is likewise the United States. 11