The country of origin of fluid ends

N351810 August 27, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Gerald Francese TradeLaw PC PO Box 1114 110 Tom Harvey Road Westerly, RI 02891 RE: The country of origin of fluid ends Dear Mr. Francese: In your letter dated July 30, 2025, you requested a country of origin ruling on behalf of your client, Jereh Energy Equipment and Technologies Corporation, to apply current trade remedies and for marking purposes. The products at issue are standard fluid ends featured as three-cylinder and five-cylinder models. The fluid ends are a component of a piston pump used in hydraulic fracturing and in the oil and gas industry. Once connected to a power end, the fluid ends pressurize fluid that is discharged through outlets. With respect to origin, two scenarios are described. In scenario one, rectangular shaped blocks are formed in China using a smelting, electroslag remelting and forging processes. The steel block forgings are then exported to South Korea to shape the outer surfaces and to drill cylinders. The unfinished blocks are then heat treated, milled, and subjected to a boring process to meet the design and dimensions of a finished product, which functions as a housing for a fluid end. The final assembly, which also occurs in South Korea, involves various processes in which components primarily sourced from China are installed into a finished block. The assembly process begins by applying grease onto the sealing surface of various seals, which are afterwards installed into their respective grooves. Next, various valves are inserted, which involves using tooling to press a valve insert into a valve body. Subsequently, discharge flanges, flange tees and O-rings are assembled to each other and then installed. Afterwards, various upper and lower valves are assembled, greased, and then inserted with springs, spring seats and spigots. Then, in sequence, packing sets, junk rings and spacer rings are installed and tightened in position, which is followed by the installation of plungers. Finally, a flange and a flange tee are attached to the fluid end, and each finished fluid end is painted, tested and packaged. For scenario two, the smelting, electroslag remelting, forging and rough machining of the blocks are completed in South Korea. The final machining of the blocks and the assembly processes described above occur in China. 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 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). Additionally, 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. CBP has held that whether a manufacturing process is sufficiently complex to rise to the level of a substantial transformation is determined upon consideration of all the operations that occur within that country. Here, the final assembly processes are rather simple and do not constitute a substantial transformation. Inserting and pressing components into a housing does not change the shape, character, or predetermined use of the inputs. Instead, we look to the origin of the housing to determine the origin of the fluid end, as it is the essential component of the product. It contributes to the pressurization process, encases the internal components, and accounts for 90 percent of the finished product’s value. Therefore, as the origin of the housing is South Korea for scenario one, the country of origin of the fluid ends (three-cylinder and five-cylinder models) for scenario one is South Korea. For scenario two, the block becomes a specialized housing in China. Therefore, as the country of origin of the housing is China, the country of origin of the fluid ends for scenario two 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, (for) James Forkan Acting Director National Commodity Specialist Division