The country of origin of a faucet

N353576 September 30, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Monique Corona Professional Plumbing Group 51 Lacrue Avenue Glen Mills, MO 19382 RE: The country of origin of a faucet Dear Ms. Corona: In your letter dated September 10, 2025, you requested a country of origin ruling on a faucet to apply current trade remedies and for marking purposes. Descriptive information was provided for our review. The product at issue is a single-handle faucet, model SB-1003-E. The brass faucet, which can be installed in a residential bathroom, is comprised of one handle, a spout, an aerator, a cover plate and a cartridge valve. The faucet will be packaged with a pop-up drain assembly. With respect to origin, the final assembly of the faucet occurs in Vietnam and begins with a cartridge valve from Vietnam undergoing various tests and inspections. Afterwards, the cartridge valve and a brass collar from China are manually pressed into a spout from Vietnam and tightened in place using a pneumatic driver. In the next step, a faucet base from China is installed onto the assembled valve body, which is followed by the installation of Vietnamese sourced hoses onto the outlets of the valve. Next, a trim washer from Vietnam is installed onto the base, mounting threads are glued in place, and the rubber and stainless-steel deck washers are mounted and secured in place using brass coupling nuts. Subsequently, a decorative cover from China is fitted onto the handle from China and fastened using a stainless-steel screw. Then, an aerator and an index temperature button are installed. Various inspections and tests are completed throughout the assembly processes and when the faucet is complete. Lastly, the finished faucet is packaged with a Vietnamese pop-up drain assembly, which is a separate valve that is opened and closed using a lift rod from 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. The final assembly processes described above are rather simple and do not constitute a substantial transformation. The processes performed in Vietnam do not change the shape, character, or predetermined use of the cartridge valve, which is recognized in Headquarters Ruling Letter H321630, dated June 27, 2022, as the essential component of faucets. Therefore, as the country of origin of the cartridge valve is Vietnam, the country of origin of the single-handle faucet is Vietnam. The country of origin of the pop-up assembly packaged with the faucet 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. 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