The country of origin of a water pump

N345436 February 5, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee DrivePeabody, MA 01960 RE:  The country of origin of a water pump Dear Ms. Murrin: In your letter dated January 27, 2025, on behalf of your client, Gates Corporation, you requested a country of origin ruling on a water pump. A Bill of Materials and a description of the assembly processes were provided in the submission. The water pump in question is designed to circulate fluid and is typically belt-driven or gear-driven by the engine. The pump primarily consists of a metal housing or composite casing that is designed to contain an impeller, a pump body, bearings, and seals. The pump is joined to a pulley to be mechanically connected to the engine's drive mechanism. The pump housing is constructed of cast aluminum or iron. Regarding origin, you describe two scenarios, in which components from various countries are exported to Mexico for final assembly. In scenario one, a Chinese manufactured Water Pump Roughcasting (housing) is placed on a fixture and a Chinese weep cover (end cover) is pressed into one of housing’s openings. In the following process, a Philippine manufactured integral shaft bearing and a Mexican seal is pressed into the opening of the housing. Next, a Mexican manufactured impeller is pressed onto the bearing shaft. Afterwards, a Chinese manufactured pulley is installed onto the bearing shaft and the housing. Once the components are appropriately placed, the components are bolted in their location. It is noted that during the final assembly processes, an O-ring and a sealing gasket from China are installed respectively. For scenario two, the final assembly occurs in Mexico and involves the same final assembly processes described in scenario one. The difference is the origin of the pulley, which is of Mexican origin in scenario two. When determining the country of origin for purposes of applying current trade remedies under Section 301, 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). Here, the final assembly processes completed for both scenarios are rather simple and do not constitute a substantial transformation. Pressing components onto the housing or shaft and securing pressed components in place using bolts are not complex in nature. The processes performed in Mexico do not change the shape, character, or predetermined use of the inputs. Therefore, like the pump end in Headquarters ruling H313089 (February 16, 2021), we rely on the origin of the impeller to determine the origin, as it is the essential component of the water pump. The impeller provides the force necessary to displace fluid. As the impeller is of Mexican origin in both scenarios, the country of origin of the finished water pump for both scenarios is Mexico, at the time of importation into the United States. 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 Sandra Martinez at sandra.martinez@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division