The country of origin of a fracking unit

N360430 April 24, 2026 OT:RR:NC:N1:102 CATEGORY: Origin Gerald Francese TradeLaw PC PO Box 1114 110 Tom Harvey Rd Westerly, RI 02891 RE: The country of origin of a fracking unit Dear Mr. Francese: In your letter dated April 3, 2026, you requested a country of origin ruling on behalf of your client, Jereh Energy Equipment and Technologies Corporation for the purpose of marking, and Section 301 Trade Remedies and other duties. The products at issue are referred to as Trailer Mounted Intelligent Electrical Fracking (TMEF) Units, model numbers YLT105-5600E, YLT95-5600E, and YLT105-6000E. Each unit consists of a trailer equipped with an electrically powered Quintuplex Plunger Pump assembly, a power assembly, high- and low-pressure assemblies, a lubrication system, a power-end lubrication assembly, a medium-voltage drive assembly, a variable-frequency drive assembly, an electrical cabinet and a control assembly. Once powered by an electric grid or a Power2Go gas turbine generator set, these assemblies work together to pump various types of fluids used for oil and gas fracturing operations. The TMEF units are differentiated by their temperature thresholds, working pressures and power output. The plunger pump assembly consists of a Quintuplex plunger pump (power and fluid ends and a reducer), a return oil pipe and a cover plate assembly. The pump, which is configured as a reciprocating positive displacement pump pressurizes the low and medium pressure water supplies and then delivers the water through a designated manifold. The power assembly consists of an oil cooler pre-assembly, a drive shaft, a medium-voltage motor and other power assembly components. Its function is to transmit power from the motor to the plunger pump via a drive shaft. The high-pressure assembly consists of a pressure sensor, a hose bracket, a wing nut and a male plug. The low-pressure assembly consists of lubrication pipe, a cast manifold, a hose bracket, an accumulator and a u-type liquid inlet. Together, the components convey the low-pressure water supply to the plunger pump. The packing lubrication assembly consists of a lubrication pump and hose connections. The function of the assembly is to lubricate the five-way packing of the plunger pump. The power-end lubrication assembly is driven by a motor that powers two double pumps, which provide lubrication for the bearings and gears inside the power end of the plunger pump. The gear pumps suction lube oil from the oil tank through suction oil filters and then deliver oil to the plunger pump via pipelines. The medium voltage drive assembly is used for electrical frequency conversion and voltage transformation to satisfy the needs of power supply scenarios. The variable frequency drive assembly consists of five outdoor units that are used to control the actuation and speed control of the lubrication motor. The electrical cabinet houses all electrical controls for the TMEF unit, including sensors, sensor cables, main motor power cables, lubrication motor power cables and other components. The control assembly is a centralized point of access for all electrical equipment and protection of equipment safety. New York Ruling N357930, dated February 18, 2026, previously addressed the country of origin for this product, which underwent final assembly in the United Arab Emirates (UAE). This submission provides additional details on the assembly process and updates the origin of certain components. Final assembly in the UAE involves installing main assemblies, either as complete units or as individual components sourced from China, onto a UAE-sourced trailer. Exceptions to Chinese sourcing include the drive shaft from Germany, the fluid end from the UAE, the five variable frequency drive units from Germany and a few components of the electrical cabinet. Additionally, the TMEF will be imported without the medium voltage drive assembly; it will be procured subsequent to importation. Before final assembly, these main assembly components undergo sandblasting and painting. During final assembly, various Chinese-sourced components, including cable clips, clamps, cable trays, grounding posts, base plates, latches, hinges, reinforced sleeves, fastening plates, brackets, fenders, and ladder brackets, are fitted and welded onto the trailer. Bracket installation requires special positioning fixtures, precision inspection tools, and fixed-torque fastening equipment. Thread locking adhesives and lock washers are applied to key connection points to improve connection reliability. Following these processes, main assemblies are mounted and secured onto the trailer with bolts and screws, either as complete units or individual components. In some instances, a multi-process coupling is completed. Fluid end installation requires thread preparation, hole tapering and other relevant machining. As needed, an anti-adhesion agent is applied, cylindrical pins are positioned, and grease is added. Once all assemblies and their individual components are secured, Chinese-sourced clamp connections and connecting pipes are attached. All electrical connections are then completed using crimping fixtures, brazing equipment, and other relevant tools. Subsequently, electrical engineers complete communication interfaces, establish control programming, and configure the diagnostic logistic design. Each TMEF unit undergoes testing. Once complete, it is covered with a tarpaulin and secured with straps. 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin 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. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (CBP) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. CBP has held that whether an assembly process is sufficiently complex to constitute a substantial transformation is determined by considering all operations that occur within the country. In this case, the assemblies and their individual components are integrated into a UAE-sourced trailer in the UAE, where they are mounted, bolted and secured to form a mobile pumping unit. Following this integration, the assemblies and components are connected using pipes, clamp connections and electrical wires. Subsequently, communication interfaces, control programming and the diagnostic logistic design are completed, all within the UAE. Taken together, these assembly processes are sufficiently complex and meaningful to result in a substantial transformation, such that the non-originating components lose their individual identities and become an integral part of a new article, a mobile TMEF pumping unit with a new name, character, and use. Therefore, based on the totality of the circumstances, the country of origin of the TMEF unit is the UAE. 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 P. Forkan Director National Commodity Specialist Division