The country of origin of plastic connectors, caps and washers

N358586 February 25, 2026 OT:RR:NC:N5:137 CATEGORY: Origin Jessica Islas-Parker A. N. Deringer 173 West Service Rd. Champlain, NY 12919 RE: The country of origin of plastic connectors, caps and washers Dear Ms. Islas-Parker: In your letter dated February 5, 2026, you requested a country of origin ruling on plastic connectors, caps and washers on behalf of your client, Meridian International Co., Ltd. The metal male and female menders will be addressed on a separate ruling. The first item under consideration is described as a 4pc Connector Set. The product consists of a hose connector, a faucet connector and two hose adapters. The components are made up of polypropylene (PP), acrylonitrile butadiene styrene (ABS) and polyoxymethylene (POM) plastics. They will be packaged together in a polybag with a header card. Female quick connector water stop: The subcomponents, female connector and female quick connector shell, are injection molded in Cambodia using Chinese raw materials. The subcomponents, thermoplastic rubber (TPR) overmolded shell, water stop plug, washer, o-ring and spring, are manufactured in China. The Cambodian origin subcomponents are shipped to China where they are combined with the Chinese origin subcomponents to form the female quick connector water stop. Male quick connector: The subcomponents, male connector and male quick connector shell, are injection molded in Cambodia using Chinese raw materials. The subcomponents, TPR overmolded shell. and spring, are manufactured in China. The Cambodian origin subcomponents are shipped to China where they are combined with the Chinese origin subcomponents to form the male quick connector. Female adapter: The subcomponent, female adapter, is injection molded in Cambodia using Chinese raw materials. The subcomponents, washer and o-ring, are manufactured in China. The Cambodian origin female adapter is shipped to China where it is combined with the Chinese origin washer and o-ring to finish the female adapter. Male adapter: The subcomponent, male adapter is injection molded in Cambodia using Chinese raw materials. The subcomponent, o-ring, is manufactured in China. The Cambodian origin male adapter is shipped to China where it is combined with the Chinese origin o-ring to finish the female adapter. The second item under consideration is described as a 10-piece cap and washer set. This product consists of eight washers and two caps to be used with hose connectors. The washers are made of TPR, and the caps are made of ABS plastic. Your submission indicates that the caps are injection molded in Cambodia and the washers are injection molded in China. They will be packaged together in a polybag with a header card. 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). You propose that both the 4pc connector set and the 10-piece cap and washer set should be considered sets for the purpose of the country-of-origin determination. The Explanatory Notes (ENs) to the Harmonized Tariff Schedule of the United States (HTSUS) constitute the official interpretation of the tariff at the international level. EN X to General Rule of Interpretation (GRI) 3(b) provides: “for the purposes of this Rule, the term "goods put up in sets for retail sale" shall be taken to mean goods which: (a) consist of at least two different articles which are, prima facie, classifiable in different headings; (b) consist of products or articles put together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking (e.g., in boxes or cases or on boards).” Each of the items in the “4pc Connector Set” are classified in the same heading. Therefore, the “4pc Connector Set” is not a GRI 3(b) set. Accordingly, the country of origin of each of these items will be determined separately. The essential character of the female quick connector water stop is imparted by the water stop plug which is injection molded in China. Accordingly, the country of origin for the female quick connector water stop will be China. The essential character, of the male quick connector, female adapter and male adapter, is imparted by the Cambodian origin subcomponents. Accordingly, the country of origin of the male quick connector, female adapter and male adapter will be Cambodia. You propose that the country of origin for the 10-piece cap and washer set should be Cambodia as the caps would predominate over the washers and impart this product with its essential character. We agree, and accordingly, the country of origin for this set will be Cambodia. 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 Christina Allen at julie.c.allen@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division