The country of origin of a Stainless-Steel Eye and Face Wash Bowl Wall Mount System

N359522 April 1, 2026 OT:RR:NC:N5:121 CATEGORY: Origin Monique Corona Professional Plumbing Group 51 Lacrue Ave Glen Mills, PA 19342 RE: The country of origin of a Stainless-Steel Eye and Face Wash Bowl Wall Mount System Dear Ms. Corona: In your letter dated March 6, 2026, you requested a country of origin ruling on a Stainless-Steel Eye and Face Wash Bowl Wall Mount System, part number SE-1055. Photographs and descriptions of the product and manufacturing process were submitted with your inquiry. The Stainless-Steel Eye and Face Wash Bowl Wall Mount System provides an immediate water source to flush the eyes and face of a user who is exposed to hazardous chemicals or harmful contaminants. It is a stainless-steel sink that has two aerated eyewash sprays and two face pads for full face cleansing. The eye and face wash bowl is activated using the handle paddle. It is an emergency station that is engineered to be wall mounted and includes wall flange and pipe for easy wall assembly. You describe a process in which the system is assembled in Thailand using components from both China and Thailand. Components from China include the drawn stainless-steel sink bowl, hose manifold tee assembly, galvanized plug, bowl mounting/supply spud, bent supply pipe, drain strainer face, dust covers, and the paddle handle. Components made in Thailand include the aerated spray assembly, the left and right non-aerated spray assemblies, and the stainless-steel ball valve. The assembly process in Thailand is described as follows: The aerated and non-aerated spray assemblies are pressed to the underside of the Chinese-origin stainless-steel bowl. The hose manifold tee assembly is connected to the aerated and non-aerated spray assemblies. The galvanized plug is attached to the bottom of the bowl mounting/supply spud unit, and the bent supply pipe and stainless-steel ball valve are secured to the sides of the unit. The drain strainer face in secured in place. The dust covers are installed on the aerated and non-aerated spray assemblies. The paddle handle is connected to the stainless-steel ball valve. The system is quality control tested and then packaged for retail sale. When determining the country of origin for purposes of applying current trade remedies under Section 301 and Section 232 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 the opinion of this office that the Chinese origin stainless-steel bowl has a predetermined end use, has the basic nature of the finished Eye and Face Wash Bowl Wall Mount System, and is not substantially transformed to become a new article having a new name, character, or use after being further processed in Thailand. Accordingly, the country of origin for the Stainless-Steel Eye and Face Wash Bowl Wall Mount System is China. This product may be subject to antidumping duties or countervailing duties (AD/CVD). When there is a question as to whether merchandise is subject to an antidumping or countervailing duty order or considered to be defined by the scope of an order, such a determination is governed by the U.S. Department of Commerce’s International Trade Administration (“Commerce”). Commerce issues scope rulings to determine whether merchandise which is in commercial production is covered by the scope of an antidumping or countervailing duty order. Commerce’s scope rulings are separate and distinct from decisions issued by CBP regarding tariff classification and country of origin for purposes such as duty assessment and marking. To seek a scope ruling, please visit the website of Commerce’s International Trade Administration. A guide to seeking a scope ruling can be found at https://access.trade.gov/help/Scope_Ruling_Guidance_(4.1.2022).pdf. A list of current AD/CVD investigations at the United States International Trade Commission can be viewed on its website at http://www.usitc.gov. Additionally, messages sent by Commerce to CBP regarding AD/CVD cash deposits and liquidation can be searched using ACE or CBP’s search tool at https://trade.cbp.dhs.gov/ace/adcvd/adcvd-public/#. 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 Jennifer Jameson at jennifer.d.jameson@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division