The country of origin of a fountain

N353152 September 23, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Sara Liu Nature’s Mark, LLC 9999 Bellair Blvd, Suite 908 Houston, TX 77036 RE: The country of origin of a fountain Dear Ms. Liu: In your letter dated September 2, 2025, you requested a country of origin ruling on behalf of your client, Walgreens Co. A description of the assembly processes was provided in the submission. The product is a tabletop fountain, item number WIC 636463. The fountain, which features LED lights, is primarily constructed of plastic and is designed for water to cascade over a rectangular-shaped background into a square base that contains stones. The water flow that travels through the fountain is generated by an internal pump. With respect to origin, the final assembly of the fountain occurs in Cambodia using components sourced from China and Cambodia, which include the outer decorative structure of the fountain and the battery box. Prior to the final assembly, plastic components are connected and glued in place to form the outer structure of the fountain. The final assembly of the fountain begins by welding a battery box to LED lights and a pump from China. Afterwards, the pump and a water pipe are installed into the structure, and the battery box is placed into the rear section of the structure. Lastly, a middle base plate is secured in place using screws. The finished fountain is then packaged with a USB cable from China and stones from Cambodia. 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 Cambodia are rather simple and do not constitute a substantial transformation. The final assembly processes performed in Cambodia do not change the shape, character or predetermined use of the inputs. Inserting a pump, a water pipe and a battery box into the outer structure of the fountain is not complex. Therefore, like the fountain in HQ Ruling Letter H288842, dated April 29, 2019, we look to the origin of the pump, as it is the essential component of the fountain. The pump is the component that produces the water flow that provides the fountain’s visual and auditory appeal. Therefore, as the origin of the pump is China, the origin of the fountain 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division