The country of origin of faucets

N347840 May 7, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Mika McLafferty Sandler, Travis & Rosenberg 675 Third Avenue, Suite 2425 New York, NY 10017 RE: The country of origin of faucets Dear Ms. McLafferty: In your letter dated April 15, 2025, you requested a country of origin ruling on behalf of IKEA Supply AG. Descriptive information was submitted for our review. The four styles of faucets at issue are the MACKSJÖN centreset washbasin mx tp 4 (MACKSJÖN tp 4), the MACKSJÖN widespread washbasin mx tp 8 (MACKSJÖN tp 8), the MACKSJÖN kit mx tp pullout with spray (MACKSJÖN pullout with spray) and the MACKSJÖN kit mx tp pulldown with spray (MACKSJÖN pulldown with spray). The faucets are used to control the flow of water released into a sink. The faucets are comprised of Chinese sourced components, hoses manufactured in Vietnam, and a subassembly manufactured in Vietnam. The final assembly of the faucets occurs in China. The cartridge valve subassembly, which controls the flow of water, is the subassembly that is manufactured in Vietnam. The cartridge valve subassemblies of faucet styles MACKSJÖN tp 4 and MACKSJÖN tp 8 consist of hot and cold valve cartridges produced in Vietnam of Vietnamese components. The cartridge valve subassembly of faucet style MACKSJÖN tp 4 also features a Vietnamese produced underbody comprised of a support plate, an end body, a central waterway, a sealing washer and a locking screw. Once the underbody is produced, the hot and cold cartridges are assembled to an underbody and tightened in place using Vietnamese manufactured cartridge nuts. Afterwards, the flexible hoses are connected to the cartridge seats. The cartridge valve subassembly of faucet style MACKSJÖN pullout with spray consists of components from China and Vietnam. The assembly process for this subassembly begins by tightening a Chinese manufactured prop up to a Chinese manufactured nipple. Next, a Vietnamese manufactured valve seat is inserted into the prop up. Afterwards, a seat is assembled to the resulting assembly and locked in position using a Vietnamese manufactured cartridge nut. The cartridge valve subassembly of faucet style MACKSJÖN pulldown with spray consists of components from China and Vietnam. The assembly process consists of assembling a Vietnamese manufactured cartridge to a Chinese manufactured sleeve and a Vietnamese manufactured seat. The components are kept in position using a cartridge nut. It is noted that the hot and cold cartridges are not assembled to an underbody for faucet styles MACKSJÖN tp 8, MACKSJÖN pullout with spray and MACKSJÖN pulldown with spray. Instead, the individual cartridges are sealed using O-rings and their respective hoses are joined to each cartridge to form waterways. For faucet style MACKSJÖN tp 8, two O-rings are assembled to the metal and plastic pipes, which are subsequently assembled to the hot and cold cartridges. Next, a card and a bushing are assembled to the pipe connector, and the flexible hoses are tightened to the metal pipes. The hoses joined to the cartridge valve subassemblies are constructed in Vietnam. The flexible hoses, which are threaded, are constructed by combining an inner hose, an outer PET braiding and connectors. The metal pipes are constructed using machining and welding processes. The plastic pipes, the connector hose for faucet style MACKSJÖN pullout with spray, and the outlet hose of faucet style MACKSJÖN pulldown with spray are constructed using plastic injection and welding processes. The bushings are constructed using a plastic injection process. Prior to being exported to China, the cartridge valve subassemblies with waterways are subjected to various inspections and testing. Once the valve subassemblies are received in China, they are combined with additional parts to produce finished faucets. Such components include a spout, handles, a base plate, and a cover plate, which are all produced, sanded, machined, notched, polished and electroplated in China. After final inspection, the faucets are packaged for shipment. Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin 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 marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that 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.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 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. A substantial transformation occurs when, as a result of the manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). The final assembly processes completed for the four faucets are rather simple and do not constitute a substantial transformation. The processes performed in China do not change the shape, character, or predetermined use of the Vietnamese produced valve subassemblies, which as discussed in Headquarters ruling H321630 (June 27, 2022), are the essential component of faucets. Therefore, as the country of origin of the cartridge valve subassemblies is Vietnam, the country of origin of the faucets is Vietnam. 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. 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 CBP Code of 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