The country of origin of a stainless-steel kitchen sink strainer assembly

N354477 October 22, 2025 OT:RR:NC:N5:121 CATEGORY: Origin, Marking Monique Corona Professional Plumbing Group, Inc. 51 Lacrue Ave Glen Mills, PA 19342 RE: The country of origin of a stainless-steel kitchen sink strainer assembly Dear Ms. Corona: In your letter dated October 1, 2025, you requested a country of origin ruling on a kitchen sink strainer on behalf of Professional Plumbing Group Inc. The merchandise under consideration is described as a sink strainer assembly. It is made of a stainless-steel strainer body with machined external threads, a stainless-steel basket and post, an iron mount yoke, solid brass lock and coupling nuts, and a neoprene stopper with a sealing tailpiece washer. It is designed for use as a replacement for standard kitchen sink strainers or for installation in new kitchen sinks. You describe a manufacturing process in which the stainer body and basket are made from Chinese-origin stainless-steel that is blanked to size in China and then shipped to Thailand. In Thailand, the strainer body is stamped, drawn, pierced, and threaded to form the main body of the strainer, and then laser etched with the brand trademark; and the basket is drawn, stamped, drawn, and pierced. The basket is then assembled with a Chinese-origin stainless-steel post and a rubber cup washer. The iron mount yoke (pressure cup) and brass nut mounting are both made entirely in Thailand with Thai-origin iron or brass. The final product is assembled together using a rubber mount washer, fiber washer, and an HDPE super seal washer from China. The fully assembled strainer is packaged in its retail packaging in Thailand for export. Country of Origin When determining the country of origin for purposes of applying current trade remedies under Section 301 or Section 232 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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). This office reviewed the provided assembly process and is of the opinion that the Chinese components undergo processing that is sufficiently complex and meaningful as to result in a substantial transformation, such that the non-originating components lose their individual identities and become an integral part of a new article, possessing a new name, character, and use. In addition, essential parts are manufactured in Thailand. Thus, from the details submitted, we agree that the country of origin for the sink strainer assembly will be Thailand. Marking 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. Part 134, Customs Regulations (19 CFR Part 134), implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Pursuant to 19 CFR Section 134.1(b), the country of origin is the country of manufacture, production or growth of any article of foreign origin entering the U.S. Section 134.1(d) defines the ultimate purchaser as generally the last person in the U.S. who will receive the article in the form in which it was imported. An article is excepted from marking under 19 U.S.C. 1304 (a)(3)(D) and section 134.32(d), Customs Regulations (19 CFR 134.32(d)), if the marking of a container of such article will reasonably indicate the origin of such article. Accordingly, if Customs is satisfied that the article will remain in its container until it reaches the ultimate purchaser and if the ultimate purchaser can tell the country of origin of the article by viewing the container in which it is packaged, the individual articles would be excepted from marking under 19 U.S.C. 1304 (a)(3)(D) and 19 CFR 134.32(d). Section 134.46, CBP Regulations (19 CFR 134.46), requires that in any case in which the words “United States,” or “American,” the letters “U.S.A.,” any variation of such words or letters, or the name of any city or locality in the United States, or the name of any foreign country or locality other than the country or in which the article was manufactured or produced, appears on an imported article or its container, there shall appear, legibly and permanently, in close proximity to such words, letters, or name, and in at least a comparable size, the name of the country of origin preceded by “Made in,” Product of,” or other words of similar meaning. In order to satisfy the close proximity requirement, the country of origin marking must generally appear on the same side(s) or surface(s) in which the name or locality or other than the actual country of origin appears. You propose that the retail packaging for the kitchen sink strainers will be marked with the following language: “WOLVERINEBRASS.COM | CONWAY, SC | 800-944-9292 | MADE IN THAILAND” The proposed marking of the imported kitchen sink strainers, as described above, is conspicuously, legibly and permanently marked in satisfaction of the marking requirements of 19 U.S.C. 1304 and 19 CFR Part 134. We find that marking the exterior packaging box is acceptable for the importation of these kitchen sink strainers and would satisfy 19 USC 1304(a)(3)(D), as the container will reasonably indicate the origin of these articles to the ultimate purchaser. We note that the retail packaging includes a U.S. city and state, however, as the country of origin language, “Made in Thailand” is in close proximity and in the same font size as the US locality, we find that it is acceptable and satisfies 19 CFR 134.46 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 Jennifer Jameson at jennifer.d.jameson@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division