The country of origin of an inflator hose adapter

N362022 June 23, 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 an inflator hose adapter Dear Ms. Tian: In your letter dated June 3, 2026, you requested a country of origin ruling on an inflator hose adapter. The inflator hose adapter, SKU SP006, is designed to inflate and deflate vehicle tires. The adapter features a metal connector and is comprised of a shell that contains a valve (a pigtail end, a pin, one of two ferrules, and a rubber gasket), a flexible hose and a handle that toggles the valve core. In use, the adapter provides a secure, leak-proof seal between the inflator and tire for the purpose of making pressure adjustments on inflatable equipment and tires of cars, motorcycles and bicycles. With respect to origin, the inflator hose adapter is assembled in Malaysia using a hose and a rubber gasket from China and components from Malaysia. The plastic components, which include the pigtail end, the pin and the handle, are produced using an injection molding process. The connector, the ferrules and the shell are formed by stamping the metal blanks. Once shaped, the metal components undergo an electroplating process. The rubber hose from China is cut to specific lengths. Final assembly involves manually assembling a cut to length hose with plastic and metal components, which includes inserting a rubber gasket. Afterwards, the components are pressed together using a hand-operated punch press and sealed using a crimping tool. 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 a significant amount of the components that comprise the inflator hose adapter are manufactured in Malaysia. These components emerge with a new name, character, and use, different from those possessed by the Polyoxymethylene material and the blank metal 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 inflator hose adapter 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