The country of origin of valves

N358157 February 27, 2026 OT:RR:NC:N1:102 CATEGORY: Origin Monique Corona Professional Plumbing Group 51 Lacrue Ave. Glen Mills, MO 19382 RE: The country of origin of valves Dear Ms. Corona: In your letter dated January 23, 2026, you requested a country of origin ruling on valves. A description of the assembly processes was provided in the submission. The four items under consideration are manually actuated valves. The valves feature a lever or a wheel and are used to control the flow of water in plumbing fixtures, such as toilets, faucets, etc. The valves will be assembled in Thailand using components from China and Thailand. With respect to item one, the full port ball valve, the assembly process begins by manually assembling a seat from China and a ball from Thailand into a brass valve body that was forged and machined in Thailand. Following that, a cap from Thailand is installed. Next, packing from Thailand and an O-ring, a packing nut, and a stem from China are press fit into place. Finally, a handle sourced from China is secured to the valve using a nut and lock washer. The finished valve is subjected to inspections and testing. The assembly of the second valve, the straight stop, begins by inserting a ball seat and compression bonnet from China into a valve body forged and machined in Thailand. A quarter-turn valve stem and O-ring are then installed through the top of the valve body. At that point, the compression bonnet and compression sleeve are secured in place using a compression nut. In the last step, a plastic handle from China is screwed onto the valve. The assembly of the third valve, an angle stop designed to turn 90 degrees, begins by inserting an O-ring, a ball seat and a ball from China into a brass body forged and machined in Thailand. Next, a valve stem and an O-ring from China are installed into the valve body through its top. A compression sleeve and compression nut from China are connected using a nut and positioned in place. A stop handle from China is then secured onto the valve using a screw. The assembly of the fourth item, a ceramic disc press angle stop, begins by inserting a Chinese-sourced cartridge valve, which is a complete valve comprised of a pressure-containing shell with a closure element and seats, into a brass valve body that is forged and machined in Thailand. After that, an O-ring from China is installed to prevent leaks. A compression sleeve and compression nut from China are installed and a stop handle from China is attached to the top of the angle stop body. Finally, the valve is subjected to inspections and testing, and a stop handle from China is attached to the top of the angle stop body. 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 these valves. In the scenarios for items 1, 2, and 3, the origin of the valve bodies is Thailand. Thus, the origin of the valves for items 1, 2, and 3 is Thailand. For item 4, the origin of the cartridge valve, which is a complete valve, is China. Therefore, the origin of item 4 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) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division