The country of origin of a Valve Fishing Tool

N361975 June 23, 2026 OT:RR:NC:N1:118 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 a Valve Fishing Tool Dear Ms. Tian: In your letter dated June 2, 2026, you requested a country of origin determination for marking purposes under Section 304 of the Tariff Act of 1930, as amended (19 U.S.C 1304). Item SP009 is identified as a Valve Fishing Tool. It is made of steel and is designed to remove and install Schrader valve cores in vehicle tires, bicycle tires, and other inflatable equipment. It allows for quick replacement of damaged or leaking valve cores, enabling tire pressure maintenance and repair, while its flexible hose design provides easy access to valve stems in tight spaces. The tool is composed of a short head, rivet, steel wire rope, lower valve core, long head, and ferrule. You have stated that the Valve Fishing Tool is manufactured entirely in Malaysia from raw steel that is sourced from Malaysia and China. The manufacturing processes that occur in Malaysia include cold extrusion, CNC machining, steel wire rope cutting, electroplating, and assembly. The finished tool then undergoes testing before it is packaged for retail sale. 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. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). Regarding the country of origin of the Valve Fishing Tool, it is our view that raw steel is substantially transformed in Malaysia into a finished tool. As demonstrated in your production flow charts, all manufacturing and finishing operations occur in Malaysia. Therefore, the country of origin of the Valve Fishing Tool, item SP009, is 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 Anthony Grossi at anthony.e.grossi@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division