The country of origin of insulated copper tubing assembled in China.

N187578 October 28, 2011 CLA-2-74:OT:RR:NC:1:117 CATEGORY: Country of Origin Mr. Greg Darter Phoenix International Freight Services, Ltd 1061 E. Northwest Highway, Suite 500 Grapevine, TX 76051 RE: The country of origin of insulated copper tubing assembled in China. Dear Mr. Darter: This is in response to your letter dated September 30, 2011, on behalf of SC Ningbo International Ltd., requesting a ruling on the country of origin of insulated copper tubing assembled in China. The item in question is a copper tubing product used in the automobile industry for air conditioning units. Comprised of copper tubing with rubber insulation, both materials are produced in South Korea. In China the two components will be joined together by simply inserting the copper tubing through a rubber insulating sleeve. The tubing is then coiled and imported into the United States. The "country of origin" is defined in 19 CFR 134.1(b) 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 this part. With respect to the insulated copper tubing, merely fitting the two components together does not result in a new product having a distinctive name, character or use. Therefore, the good remains a product of South Korea. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). 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, contact National Import Specialist Mary Ellen Laker at (646) 733-3020. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division