The country of origin of a stainless steel corrugated connector

N355143 November 19, 2025 OT:RR:NC:N1:164 CATEGORY: Origin Peiting Liang Taizhou Kloe Dafeng Plumbing Co., Ltd. No.1, Shitai Road, Yuhuan Economic Development Zone Taizhou 317608 China RE: The country of origin of a stainless steel corrugated connector Dear Peiting Liang: In your letter dated October 22, 2025, you requested a country of origin ruling on a stainless steel corrugated connector. Product information was submitted with your request. The item under consideration is described as a stainless steel corrugated connector to connect a water supply to a water heater. You state the length will range between 12 and 36 inches. The corrugated tube is made from stainless steel strip and the two ends will feature various types of stainless steel or brass fittings. You specify that for the purposes of this ruling, the end fittings will be 3/4-inch female and 3/4-inch push-to-connect. In your submission, you provided a description of the production process and an exploded diagram for the stainless steel corrugated connector. The production process begins in Thailand where the raw material is made into stainless steel strip that is welded to the tube. Then, the tube undergoes a corrugating process, is cut to the specified length, and flattened on both ends. Also, end fitting blanks and corresponding nuts are forged in Thailand to the approximate shape and size of finished end fittings. In China, the forged end fitting blanks and nuts from Thailand undergo machining processes which result in finished end fittings. After that, the end fittings will be combined with several components of Chinese origin, such as washers, sleeves, and O-rings, and assembled onto the ends of the tube. Finally, the finished stainless steel corrugated connector will be packed in cartons and shipped to the United States. 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). It is clear from your submission that the functionally prominent constituents of the stainless steel corrugated connector are the stainless steel corrugated tube and end fitting components. In this scenario, cut-to-length and fully formed stainless steel corrugated tube from Thailand is shipped to China with a predetermined function as a flexible yet robust connection for water to travel from a water supply to a water heater. Additionally, the end fittings and corresponding nut blanks are forged in Thailand. Though they are not fully functional, they are formed to the approximate shape and size of the finished end fittings. After forging, the end fitting components are shipped to China where they undergo machining to prepare the surfaces for use. Based on your description, the machining of the end fitting components in China does not constitute a substantial transformation because they retain the name, character, and use acquired from forging in Thailand. In addition, the simple assembly by combining the primary connector components from Thailand with less-significant Chinese components in China does not substantially transform them. In totality, no new article emerges from processing in China with a new name, character, or use different from that possessed prior. Accordingly, the country of origin of the stainless steel corrugated connector is Thailand. This determination is distinguished from the scenario at issue in New York Ruling Letter N344930, dated January 22, 2025. Although that ruling pertained to identical merchandise, the facts underlying the origin determination were materially different. Specifically, the end fitting components were manufactured in China, not Thailand. 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 (C.F.R.), 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 C.F.R. 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 Paul Taylor at paul.m.taylor@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division