The country of origin of a pop-up drain assembly

N359281 March 25, 2026 OT:RR:NC:N1:102 CATEGORY: Origin Monique Corona Professional Plumbing Group 51 Lacrue Avenue Glen Mills, PA 63368 RE: The country of origin of a pop-up drain assembly Dear Ms. Corona: In your letter dated February 27, 2026, you requested a country of origin ruling on a pop-up drain assembly. Descriptive information regarding the assembly process was provided in the submission. The product in question is a pop-up drain assembly, part number 40VA00102CP-XXXX. The assembly primarily consists of a drain body assembly (a stopper assembly within a drain and tail pipe unit) and an actuator (a rod assembly), which are packaged together ready for retail sale. In use, the rod assembly is manually pulled, allowing the stopper assembly to be raised. As the stopper assembly is lifted, sink water is released into a drainpipe. With respect to origin, the product is assembled in Vietnam using components sourced from Vietnam and China. The final assembly begins by aligning the drain body sourced from Vietnam with the threads of a lock nut from Vietnam. Once aligned, the lock nut is manually screwed into the body. A washer and gasket are manually positioned and pressed into position. Next, a slide nut from China is screwed onto the drain body and an O-ring from Vietnam is pressed onto the stopper assembly from China. Adhesive is then applied and cured. The assembly process continues by screwing a tail pipe from Vietnam to the drain body. The finished drain assembly is then packaged with an actuator (a rod and ball assembly from Vietnam, and lower pull and lift rods from China) and other components, such as a seat gasket from China, a spring cup from Vietnam and a set screw from Vietnam. 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). Here, the processes that occur in Vietnam are simple and do not constitute a substantial transformation. To assemble the pop-up drain, components are either pressed into or screwed onto the drain body and tail piece unit to form a drain body assembly. The completed drain body assembly is then packaged with the components of the actuator. The assembly and packaging processes performed in Vietnam do not change the shape, character, or predetermined use of the inputs. Accordingly, we look to the origin of the drain body and the tail piece unit, which are the essence of a pop-up drain assembly based on their bulk and role. The stopper assembly and actuator would not be able to function without the drain body and tail piece unit. Therefore, as the origin of the drain body and tail piece unit is Vietnam, the origin of the pop-up drain assembly is Vietnam. 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