The country of origin of insulated copper tubing

N284627 April 21, 2017 MAR-2 OT:RR:NC:N1:117 CATEGORY: Country of Origin Mr. Craig K. Hickam Toll Global Forwarding (USA) Inc. 150-15 183rd Street Springfield Gardens, NY 11413 RE: The country of origin of insulated copper tubing Dear Mr. Hickam: This is in response to your undated letter received by our office on March 22, 2017, on behalf of Icool USA Incorporated, requesting a ruling on the country of origin of insulated copper tubing assembled in China. A representative sample was included with your request and will be returned to you. The item in question is insulated copper tubing used in the automobile industry for air conditioning units. You indicate that copper tubing, produced in South Korea, will be shipped to China where it will be inserted through a polyethylene (PE) insulation tube of Chinese origin. The copper tubing is then cut to a specific length, coiled and packed in a cardboard box before being imported. 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, fitting the two components together, cutting to length and coiling the tubing does not result in a new product having a distinctive name, character or use. Therefore, in our opinion, 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 mary.ellen.laker@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division