The country of origin of showerheads

N354105 October 17, 2025 OT:RR:NC:N4:422 CATEGORY: Origin, Marking Ms. Monique Corona Professional Plumbing Group Inc. 51 Lacrue Ave Glen Mills, PA 19382 RE: The country of origin of showerheads Dear Ms. Corona: In your letter dated September 23, 2025, you requested a country of origin ruling on two showerheads. Product images, Bill of Materials (BOM) were submitted with your request. Item description 1 - The merchandise is described as a showerhead. It features spray settings with six spray patterns. The article is available in chrome finish and contains a plastic flow control unit that regulates water flow to a specific rate and does not contain a valve. In your letter, you indicated that all parts are sourced from China and Germany as follows: Components of Chinese Origin Coupling Nut Spindle Nut Spindle 6-Jet Handle Screw Cap Plunger Guide 2.5 GPM Plunger Plunger Holder Split Ring Shank 2.5 GPM 6-Jet Index Plate Wear Plate Wear Plate #10-24 Machine Screw #6-32 Machine Screw Shower Swivel Ball O-Ring, Water Line O-Ring, Lubricated O-Ring, 4mm x 7.6mm Face Plate Plunger Cap Strained Washer Component of German Origin Flow Controller All of the components are shipped to Thailand. The assembly and manufacturing processes, including inspection and packaging, are performed in Thailand: Swivel Ball Assembly, Spray Assembly, Handle Assembly, Final Assembly, Testing, Final Inspection, and Packaging. Item Description 2 -The merchandise is described as a showerhead. It features spray settings with five spray patterns. The article is available in chrome finish and contains a plastic flow control unit that regulates water flow to a specific rate and does not contain a valve. In your letter, you indicated that all parts are sourced from Thailand, China and Germany as follows: Components of Thailand Origin Insert Body Connecting Tube Spray Surface Components of Chinese Origin Sealing Part Adjusting Body Connecting Thread Handle Handle Screw Nut Shank Quad Ring Seven different types of O-Ring’s Showerhead Ball Plungers Plunger Cap Message Body Turbine Cover Plate Mesh Washer Faceplate Ring Handle Hole Cover Components of German Origin Flow Control All of the components are shipped to Thailand. The assembly and manufacturing processes, including inspection and packaging, are performed in Thailand: Mold Injection Process, Showerhead Ball Assembly, Spray Assembly, Handle Assembly, Final Assembly, Testing, Final Inspection, and Packaging. 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). 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 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). This office reviewed the provided assembly process information, and is of the opinion that the Chinese, the German, and the Thailand components undergo processing in Thailand which results in a substantial transformation, such that these components lose their individual identities and become an integral part of a new article, possessing a new name, character, and use. Accordingly, from the details submitted, we agree that the country of origin for Item Descriptions 1 and 2, both showerheads would be Thailand. The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. 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 U.S. the English name of the country of origin of the article. As provided in section 134.41(b), Customs Regulations (19 CFR 134.41(b)), the country-of-origin marking is considered conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read it without strain. With regard to the permanency of a marking, section 134.41(a), Customs Regulations (19 CFR 134.41(a)), provides that as a general rule marking requirements are best met by marking worked into the article at the time of manufacture. For example, it is suggested that the country of origin on metal articles be die sunk, molded in, or etched. However, section 134.44, Customs Regulations (19 CFR 134.44), generally provides that any marking that is sufficiently permanent so that it will remain on the article until it reaches the ultimate purchaser unless deliberately removed is acceptable. As the article is not currently marked, it does not satisfy the marking requirements described above. When you have a sample that is marked in accordance with the requirements described above, you may request a country of marking binding ruling. If you decide to resubmit your request, please include photos of the marked sample. 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 Dana L. Giammanco at dana.l.giammanco@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division