The country of origin of a paint sprayer

N362121 June 26, 2026 OT:RR:NC:N1:105 CATEGORY: Origin Mark Baxa FerniaCreek Global Supply Chain Consulting Group 2208 Missouri Blvd, Suite 102 Jefferson City, MO 65109 RE: The country of origin of a paint sprayer Dear Mr. Baxa: In your letter dated June 7, 2026, on behalf of your client, Chervon North America, Inc., you requested a country of origin ruling on a paint sprayer. Descriptive literature was provided for our review. The item under consideration is described as a paint sprayer, which is a high-volume, low-pressure (HVLP) handheld electric sprayer designed to atomize low-viscosity liquids into a fine mist for finishing applications. The sprayer is intended for spraying interior and exterior walls, floors, furniture, wooden products, railings, doors, windows, cabinets, tables, chairs, and other small to medium-sized areas commonly encountered in residential and light commercial finishing work. In operation, the motor generates air pressure where a portion enters the tank through the intake pipe forcing the liquid through the siphon tube to the nozzle. Simultaneously, another portion of the air pressure atomizes the liquid exiting the nozzle into a fine mist for application. The paint sprayer itself consists principally of an ergonomic plastic handle and motor housing, an on/off switch and switch lever assembly, a paint container with internal suction tube, a flow control knob, a tip collar, an air cap, a set of interchangeable nozzles (1.3 mm, 1.5 mm, 2.0 mm, and 2.5 mm sizes), a spray width control lever, a filter and filter housing, an air tube and check valve assembly, and a brushless motor and printed circuit board assembly (motor/PCBA) housed within the motor enclosure. The product has a maximum flow rate of 833 ml/min (28 oz/min) and a paint container capacity of 1,200 ml (40 fl. oz.). The 24V 2.0 Ah lithium-ion battery pack is a removable rechargeable battery designed for use with the sprayer and other compatible Kobalt 24V cordless tools. The battery pack incorporates protection circuitry that guards against extreme temperature, over-discharge, and overcharge conditions, and features a four-LED power indicator that displays the remaining state of charge. The compatible battery charger is an AC-powered charging station that recharges a fully discharged 2.0 Ah battery pack in approximately 85 minutes. The battery pack and charger are designed to interlock with the bare tool and with each other through specified raised ribs and slots, ensuring proper electrical contact during use and during charging. Components and subassemblies for the paint sprayer kits are sourced from Thailand, Vietnam, China, and Malaysia, with final integration occurring in Thailand. The most critical subassembly, the brushless motor and printed circuit board assembly (PCBA), is manufactured in Vietnam. The Vietnamese operations for the motor/PCBA assembly encompass a comprehensive process, including automated press-fitting of balance rings and bearings onto the rotor shaft, automated adhesive dispensing and magnet installation, and dynamic balance testing with material removal for out-of-tolerance rotors. This is followed by machine winding of enameled wire onto stator laminations, terminal crimping, and stator testing via a diagnostic instrument. Further steps involve adhesive bonding and press-fitting of the stator into the motor housing, installation of the bracket, volute case supplement, impeller, fan cover, and sealing ring. An adhesive bead is then applied, and the rear cover is installed, leading to motor break-in and thermal curing. The process concludes with the soldering of brushless motor phase wires to the PCBA pads, locked-rotor and power-on testing, performance testing, visual inspection of solder joints, application of dustproof pieces and labels, and finally, the packing of the finished motor/PCBA assembly for shipment. Additionally, the battery charger is also produced in Vietnam, while the battery itself is manufactured in Malaysia. Other components used in the sprayer are sourced predominantly from China and Thailand. Components made in China include the gun set assembly hardware (nuts, air cap, 2.0 mm nozzle, adjust knob, gun set, O-rings, compressed spring, tube, connector, valve, suction tube, and seal), cylindrical pin, buckle, push rod, pressure spring, motor support, motor sealing ring, screws, switch, battery clip, air filter, additional cleaning accessories, the 2.5 mm and 1.5 mm nozzles, and a stripe label. Components made in Thailand include the regulator knob, the paint tank, the main housing assembly, the air inlet cover, the 1.3 mm nozzle, the retail bag, and the printed packaging carton. Thai-made plastic parts are produced in Thailand through injection molding and blow molding of plastic resins. The Vietnam-origin motor/PCBA assembly is subsequently imported into Thailand, where it is integrated with the housing, gun set assembly, paint container and suction system, air inlet components, switch, controls, fasteners, and other functional and structural parts to produce the completed paint sprayer. The processing operations performed in Thailand include the assembly of the motor/PCBA into the housing using tooling fixtures, followed by performance testing of the resulting subassembly, along with the air filter and air inlet cover. Additional flow-control and structural components are then assembled, including the gun mount component, which undergoes rotational and water spray testing. The final stages involve labeling, charging the battery, placing the sprayer, battery, charger, and accessories into the printed color box, and outer carton packing. 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). Regarding the origin of the paint sprayer, in our opinion, the Vietnamese-origin motor/PCBA assembly is transformed into a finished paint sprayer in Thailand. As imported, the motor/PCBA assembly cannot draw paint, atomize liquids, or deliver a controlled spray pattern in the absence of the gun set, paint container, suction tube, valves, nozzles, air cap, flow and width controls, filter system, switch, housing, and battery interface that are integrated with it in Thailand. The Thai operations transform the imported motor/PCBA assembly together with Thai-origin and Chinese-origin components into a new and different article of commerce, namely a finished handheld HVLP paint sprayer with a distinct commercial name, character, and use that none of the individual imported components possess. Accordingly, the origin of the paint sprayer is Thailand, which is where the plastic components are manufactured and the remaining foreign components are turned into a finished paint sprayer. 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division