The country of origin of a copper corrugated connector

N357122 January 9, 2026 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 copper corrugated connector Dear Peiting Liang: In your letter dated December 17, 2025, you requested a country of origin ruling on a copper corrugated connector. Product information was submitted with your request. The item under consideration is described as a copper corrugated connector to connect a water supply to a water heater. You state that the corrugated tube will range between 12 and 36 inches in length and will feature various types of stainless steel or brass fittings. For the purposes of this ruling, both end fittings will be 3/4-inch female brass nuts. In your submission, you provided a description of the production process and an exploded diagram of the copper corrugated connector. Production begins in Thailand where Thai-origin copper tubes will be corrugated. Additionally, brass rod will be cut to length and forged into end fitting blanks in the approximate size and shape of finished end fittings. Production then moves to China where the corrugated tubes will undergo acid cleaning and annealing. Also, the end fitting blanks will undergo machining processes which result in finished end fittings. After that, the end fittings will be combined with washers and sleeves of Chinese origin and assembled onto the ends of the corrugated tube. Finally, the fully assembled, finished copper 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 copper corrugated connector are the corrugated tube and end fittings. In this scenario, cut-to-length and fully formed copper corrugated tube from Thailand is shipped to China with a predetermined use as a flexible yet robust connection for water to travel from a water supply to a water heater. Although you state that the corrugated tubes will be annealed in China, this will not constitute a substantial transformation. Based on the available information, the annealing process in this scenario merely furthers the use established during primary forming processes in Thailand (Headquarters Ruling Letter H317502, dated March 26, 2021). Additionally, the end fittings are forged in Thailand. Though they are not fully functional when exported from Thailand, they are formed to the approximate shape and size of the finished end fittings. In China, they undergo machining to prepare the surfaces for use but are not substantially transformed. Furthermore, the simple assembly process of combining the copper corrugated tube and brass end fittings 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 copper corrugated connector will be 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division