The country of origin of valves

N355399 November 20, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Lynsey Townley Crane Company 100 First Stamford Place, Suite 400 Stamford, CT 06902 RE: The country of origin of valves Dear Ms. Townley: In your letter dated October 29, 2025, you requested a country of origin ruling on valves. A description of the assembly processes was provided in the submission. The items at issue are referred to as a 2-inch lined ball valve, part number 6H3010, and a 6-inch lined butterfly valve, part number: 889508A. The ball valve is comprised of a body and a flange that primarily house a stemmed ball, seals, a steel cover and a lever. The butterfly valve is comprised of a disc, an O-ring, a washer, a seal ring, and a liner within a valve body that consists of upper and lower halves. Both valves are primarily constructed of ductile iron. Some components of the valves are coated with Perfluoro-alkoxy (PFA) material to prevent corrosion and harsh treatments that result from being in contact with liquid or gases. With respect to the ball valve, you explain the final assembly occurs in Hungary using a body, a flange and a stemmed ball sourced from India. Prior to the final assembly, the body, flange and stemmed ball are cleaned and sand-blasted in Hungary. Then, these components are pre-heated and subjected to injection and transfer modeling processes to coat the components with PFA material. Afterwards, the body, flange, and ball are deburred and painted. During the final assembly, a ball and a German seat are inserted into a valve body, and a flange is placed over the ball and screwed in place. Next, a seal from India is placed onto the ball stem, and then a steel cover from Hungary and a lever are installed onto the valve. Finally, the valve undergoes inspections, testing and is packaged. The butterfly valve is also assembled in Hungary using a valve body from China and other components from Hungary, the Czech Republic and China. Prior to the final assembly, a valve body is machined to form mounting bores that allow the valve to be positioned with pipes. Next, a liner, and a disc from China are coated with PFA material. Once the coating process is complete, a deburring process occurs. Afterwards, a seal ring from the Czech Republic and a disc are inserted into a lower valve body. An upper body is then positioned onto the lower body and bolted in place. Subsequently, a spacer from Hungary, O-rings from Germany, a wedge ring from Hungary and a washer from Germany are installed onto the upper section of the valve body. During the assembly steps, lubrication is applied. Once the valve is complete and undergoes inspections and testing, a dust cover ring is placed onto the valve. 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). When determining the country of origin of valves, CBP has relied on the origin of the valve body, the essential component of a valve, as the process of assembling a valve is rather simple. Components are typically assembled into a valve body by inserting, pressing and screwing components to each other. See New York Rulings N339513, dated May 6, 2024, N338713, dated April 3, 2024, N325765, dated May 26, 2022, and N322652, dated December 2, 2021. Therefore, as the processes described above do not result in a substantial transformation, we rely on the origin of the valve bodies to determine the origin of the ball and butterfly valves. In the scenarios described above, the valve bodies of the ball and butterfly valves are sourced from India and China, respectively. In Hungary, these items are cleaned, coated with PFA, deburred and then painted. These processes do not substantially transform the valve bodies into a new and different article of commerce with a name, character, and use distinct from the article exported from India or China. As entered into Hungary, these items are recognizable as valve bodies configured to incorporate a ball or a disc to control the flow of fluid. Accordingly, the county of origin of the ball valve is India and the country of origin the butterfly valve 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division