The country of origin of a steel corrugated connector

N359614 March 18, 2026 OT:RR:NC:N1:113 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 steel corrugated connector Dear Peiting Liang: In your letter dated March 10, 2026, you requested a country of origin ruling on a steel corrugated connector. Descriptions, technical information, and photographs were submitted with your request. The item under consideration is described as a stainless steel corrugated connector to connect a gas supply to other utilities that use gas for their operations such as water heaters, ranges for cooking, and dryers. You state the length will range between 12 inches and 72 inches. The corrugated tube is made from stainless steel strip, and the two ends will feature metal fittings, specified as 3/4 – 14 National Pipe Taper (NPT). In your submission, you provided a description of the production process and a diagram for the corrugated connector. The raw materials to produce the tube and the fittings are both from Thailand. The production process for the tube in Thailand includes shaping and welding a stainless steel strip into a tube, putting it through a corrugating process, cutting it to a specified length, and flattening both ends. The fittings are also produced in Thailand through forging the raw materials, metal blanks, into their approximate shape and size. At this point, the tube and fittings are shipped to China where the fittings undergo machining processes which result in the finished end fittings. The fittings are then assembled onto the ends of the tube creating the final product which is 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). The manufacturing processes and materials used to produce the corrugated connector are similar to those described in New York Ruling N355143, dated October 22, 2025. The tube is fully formed, corrugated, and cut-to-length in Thailand. Before it is shipped to China, the tube has a predetermined function as a connector to a gas supply and other gas-powered utilities. The fittings are forged in Thailand, although they are not fully functional, they are formed to the approximate shape and size of the finished end fittings. After forging, the fittings are shipped to China where they undergo a machining process to prepare their surfaces for use. The machining of the fittings in China do not constitute a substantial transformation because they retain the name, character, and use acquired from forging in Thailand. In totality, no new article emerges when the final product is assembled in China from that possessed prior. Accordingly, the country of origin of the stainless steel corrugated connector is 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 (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 Matthew Gay at matthew.gay@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division