The country of origin of five breast pump accessory kits

N359645 April 2, 2026 OT:RR:NC:N4:422 CATEGORY: Origin; Marking Mr. James Choi Cimilre Co., Ltd. 97-14 Seongnam-ro, Mokcheon-eup, Dongnam-gu Cheonan-si 31234 Korea, South RE: The country of origin of five breast pump accessory kits Dear Mr. Choi: In your letter dated March 11, 2026, you requested a country of origin and marking ruling of five breast pump accessory kits. A product image and a photo of tubing were submitted with your request. The five items will be addressed herein. The items concerned are five breast pump accessory kits as follows by item and model number: 1. 16mm Collection Kit / CM0A21 2. 19mm Collection Kit / CM0A14-19 3. 21mm Collection Kit / CM0A15-21 4. 24mm Collection Kit / CM0A12-24 5. 28mm Collection Kit / CM0A13-28. Each kit contains two breast shields (flanges), two silicone valves used to regulate suction, two diaphragms, two feeding bottle sets consisting of a bottle, sealing disc, and locking ring, two tubes used to connect the breast pump motor unit to the breast shield assembly. All of the components are made from polypropylene (PP) plastic and silicone materials commonly used in breast pump accessories. They are compatible with the following breast pumps: Spectra® S1 Plus, Spectra® S2 Plus, Spectra® S9 Plus, and Spectra® Synergy Gold. In your letter, you indicated that all parts are sourced from China and South Korea as follows: Component of Chinese Origin Tubing (silicone) Components of Korean Origin Diaphragm- Back Cover (PP plastic) Diaphragm Membrane (silicone) Diaphragm - Front Cover (PP plastic) Breast Shield - Flange (PP plastic) Duckbill Valve (silicone) Feeding Bottle Container (PP plastic) Feeding Bottle Cap (PP plastic) Feeding Bottle Nipple (silicone) Feeding Bottle Locking Ring (PP plastic) Feeding Bottle Disc (PP plastic) You stated that most components of each kit are manufactured in South Korea. The tubing components are manufactured in China and imported into South Korea for inclusion in each accessory kit. All components are inspected, combined, and packaged together into a retail accessory kit. No additional manufacturing processes are performed on the tubing after importation into South Korea other than inclusion in the retail packaging. Country of Origin: When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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 household articles listed in EN 39.24(C) are utilitarian and decorative in character or function as a receptacle, and are closely associated with household functions and activities, e.g., dustbins and buckets for cleaning, watering cans for watering plants or a garden, and food storage containers which store food products for, and in, a household. Like the examples provided by EN 39.24(C), the two feeding bottle container components of the breast pump accessory kit are utilitarian, made of plastic, and used in a household. They are closely associated with the household activities of childrearing, pumping breast milk, and feeding a baby. The bottle containers function as a food storage container for collecting and storing breast milk before feeding an infant. It is this office’s opinion that the primary function of each breast pump accessory kit is to collect and store breast milk before feeding an infant. The bottle containers which originate in South Korea, provide the essential element for each breast pump accessory kit. They are not substantially changed by the addition of Chinese origin components. In view of these facts, the country of origin for five breast pump accessory kits is South Korea. Marking: The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the United States shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States the English name of the country of origin of the article. Part 134, Customs Regulations (19 CFR Part 134), implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.41(b), Customs Regulations (19 CFR 134.41(b)), mandates that the ultimate purchaser in the United States must be able to find the marking easily and read it without strain. Section 134.1(d), defines the ultimate purchaser as generally the last person in the United States who will receive the article in the form in which it was imported. If an imported article is to be sold at retail in its imported form, the purchaser at retail is the ultimate purchaser. In this case, the ultimate purchaser of the cookware is the consumer who purchases the product at retail. Section 134.43(e), Customs Regulations (19 CFR § 134.43(e)), states in pertinent part, that: Where an article is produced as a result of an assembly operation and the country of origin of such article is determined under this chapter to be the country in which the article was finally assembled, such article shall be marked, as appropriate, in a manner such as the following: (1) Assembled in (country of final assembly); (2) Assembled in (country of final assembly) from components of (name of country or countries of origin of all components); or (3) Made in, or product of, (country of final assembly). In the instant case, because the breast pump is assembled in South Korea from components of China, section 134.43(e)(2) is applicable. Where, as in this case, the country of assembly is the country of origin of the article, there is no requirement that the country of origin marking include the origin of the components utilized in the foreign assembly. However, your proposed marking would only identify the origin of China made components and not the Korean. In HRL 560933, this office ruled that where U.S. components and other foreign components were used to assemble the final product in a third country and the importer wishes to identify the origin of the components, the appropriate marking is “Assembled in [country X] from components of U.S. and foreign origin.” Therefore, a marking such as “Assembled [or Made] in South Korea of China components” would be acceptable. 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 Dana L. Giammanco at dana.l.giammanco@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division