The country of origin of hypodermic syringes with needles

N344695 January 6, 2025 OT:RR:NC:N3:135 CATEGORY: Origin Timothy Allwine Neogen Corporation 1847 Mercer RdLexington, KY 40511 RE:  The country of origin of hypodermic syringes with needles Dear Mr. Allwine: In your letter dated December 17, 2024, you requested a country of origin ruling on hypodermic syringes with needles for animal use. In China, hollow steel tubes of Chinese origin will be cut to length and cut or sharpened to a sharp tip on one end, resulting a basic steel needle. A Chinse hub will then be attached to the blunt end of the needle with adhesive. These hubbed needles will be exported to Cambodia for final production. In Cambodia, plastic syringe parts (barrels with tips, plungers, and plunger seals) and plastic needle caps are produced by injection molding.  The graduated markings will be printed on the barrels in Cambodia.  The plastic syringe parts will be assembled into syringes, the hubbed needles will be attached to the syringes by screwing them in, and the plastic caps will be attached to the needles. The hypodermic syringes with needles will be sterilized, packaged, and exported to the United States.  When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). In this case, the assembly of the final syringes and the manufacture of the plastic syringe parts in Cambodia when considered together create a new article with a new name, use, and character and constitute a substantial transformation. As such, the country of origin of the hypodermic syringes with needles is Cambodia. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Fei Chen at fei.chen@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division