The country of origin of condensate pumps

N347899 May 2, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Nathan Clem Franklin Electric 9255 Coverdale Rd Fort Wayne, IN 46809 RE: The country of origin of condensate pumps Dear Mr. Clem: In your letter dated April 16, 2025, you requested a country of origin ruling on a condensate pump. Descriptive information was provided with your submission. The products under consideration are Little Giant’s VCCA-20uls condensate pumps, item numbers 554201101 and 554202101. Item numbers 554201101 and 554202101 feature a plastic enclosure, a float switch, a safety switch, a 1/2-gallon tank capacity, an impeller and a 1/30 horsepower motor. In use, the condensate pumps automatically collect and remove condensate from air conditioning, refrigeration and dehumidification equipment. With respect to origin, it is explained that the final assembly of each pump occurs in Thailand using components that are sourced from China. Prior to the final assembly, the Chinese sourced components are combined to produce various subassemblies. The subassemblies produced in Thailand are the overflow detection switch subassembly, the motor subassembly, the float subassembly and the tank cover subassembly. The assembly of the overflow detection switch subassembly, which consists of a micro-switch, a float, and a bracket, begins by screwing a float to a lever. A switch is then inserted into a bracket and snapped in place. The assembly of the motor subassembly, which is comprised of a motor, motor mounting plate, and a water slinger, consists of screwing a motor mounting plate onto a motor, and is followed by the placement of a water slinger onto the shaft of the motor. The assembly of the float subassembly, which consists of a float, a float pin, and a snap ring, begins by inserting a positioning pin into a bottom mold. A float is then placed on top of the pin and compressed in place. Afterwards, a snap ring is inserted into the float pin and pressed into position. The tank cover subassembly consists of a tank cover, an operating switch, a micro-switch clip, a float subassembly, a positioning plug and an overflow detection switch subassembly. During the assembly process, a float subassembly is installed into the tank cover and held in place using a snap ring. Next, the operating switch is pressed into the micro-switch clip and the hole in the lever arm of the switch is placed over the float rod. Afterwards, a positioning plug is installed onto the float pin and a microswitch clip is snapped on the tank cover. Subsequently, the overflow detection switch subassembly is installed into the tank cover and screwed in place. The final assembly of the pump, which takes place in Thailand, begins by screwing a motor subassembly onto a tank cover subassembly. Afterwards, a fan and an impeller are pressed onto the motor shaft using a pneumatic press. The volute is then pressed and welded onto the bottom of the tank cover. The electrical components (wiring harness, terminals and electrical leads) are connected and a motor cover is installed and screwed in place. Lastly, four feet are installed. Throughout these steps, multiple inspections and tests are conducted. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters (HQ) Ruling Letter 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 instance, the final assembly processes that occur in Thailand are rather simple and do not constitute a substantial transformation. Press fitting and screwing components in place are not complex in nature. Therefore, like the condensate pump discussed in New York ruling N316993, dated February 12, 2021, we look to the origin of the Chinese motor subassembly, as it is essential component of the pump. Accordingly, the country of origin of Little Giant’s VCCA-20uls condensate pumps, item numbers 554201101 and 554202101, is China. 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