The country of origin of valve cores

N361779 June 16, 2026 OT:RR:NC:N1:102 CATEGORY: Origin Fangyi Tian Autowin Group Limited Flat/RM 08, 15/F Witty Commercial Building 1A-1L Tung Choi Street Mongkok, Kowloon, Hong Kong China RE: The country of origin of valve cores Dear Ms. Tian: In your letter dated May 26, 2026, you requested a country of origin ruling on valve cores. The items under consideration are four red valve cores packaged together ready for retail sale (item number SP016). Each valve core functions as a tire valve that consists of a thimble, a core sleeve, a threaded head, a spring and a sealing ring. With respect to origin, each valve core is assembled in Malaysia using components from Malaysia and a spring ring from China. Prior to final assembly, raw material (copper rods) undergoes machining to form a thimble, a core sleeve, and a threaded head. Afterwards, the thimble, the core sleeve and the threaded head are electroplated. For the spring from China, glue is applied and afterwards it is wound and electroplated. Final assembly involves inserting or screwing a thimble, a core sleeve, a threaded head, and a rubber seal, all manufactured in Malaysia, into one another. A spring is also installed. The components are then pressed together, and two crimp/rivet points are used to secure the components. Lastly, each valve core is packaged on a blister card to complete item number SP016. 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. Based upon your description of the manufacturing operations, we note that virtually all of the components of each valve core are manufactured in Malaysia. These components emerge with a new name, character, and use, different from that possessed by the copper rods from which they were formed. Subsequent to the manufacturing processes, the components are assembled to each other in Malaysia. Thus, based on the totality of the circumstances, the country of origin of the valve cores will be Malaysia. 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