The country of origin of stainless steel PEX pipe fittings

N362609 July 21, 2026 CLA-2-73:OT:RR:NC:N5:116 CATEGORY: Classification; Origin TARIFF NO.: 7307.19.9060; 7307.19.9080 Stephen L. Fodor Customs Services & Solutions Inc. 6576 Church Street Douglasville, Georgia 30134 RE: The country of origin of stainless steel PEX pipe fittings Dear Mr. Fodor: In your letter received by our office on June 17, 2026, you requested a country of origin ruling on behalf of your client, Metalworks Ningbo Aida Inc. The products under consideration are identified as drop ear (model # SSPEX-DE, SSCEP-DE), male elbow (model # SSPEX-ME, SSCEP-ME), and tee (model # SSPEX-T, SSCEP-T) PEX fittings. These fittings are made from type 304 cast stainless steel and are used in plumbing water systems. Representative photos were included with your submission. The drop ear fitting (model # SSPEX-DE, SSCEP-DE) is a type of elbow fitting with a 90-degree bend and built-in mounting "ears" (tabs) that have screw holes which allow the fitting to be anchored to wall studs or backing boards. This fitting is internally threaded on one end which attaches to a pipe/tube and is barbed on the other end which attaches to a plastic PEX pipe. The male elbow fitting (model # SSPEX-ME, SSCEP-ME) is bent to a 90-degree angle and has one externally threaded end that attaches to a rigid pipe/tube and a barbed end that attaches to a plastic PEX pipe. The tee fitting (model # SSPEX-T, SSCEP-T) has three barbed ends that attach to plastic PEX pipes. You indicate that the connection to the fitting is made with either a crimp ring, pinch clamp, or cold expansion sleeve. The drop ear, male elbow, and tee fittings attach pipe made of a single extruded compound to pipe. For tariff purposes, these products are considered pipe fittings. The applicable subheading for the drop ear and male elbow fittings will be 7307.19.9060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel: cast fittings: other: other: other: other: threaded. The rate of duty will be 6.2 percent ad valorem. The applicable subheading for the tee fitting will be 7307.19.9080, HTSUS, which provides for tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel: cast fittings: other: other: other: other: other. The rate of duty will be 6.2 percent ad valorem. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. When determining the country of origin for duty purposes and for the purposes of applying current trade remedies under Section 232 and 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). According to your submission, all three types of fittings are manufactured in a similar fashion. Raw stainless steel fitting bodies are cast in China and sent to Cambodia where the inside and outside diameter, threads, and barbs of the fittings are CNC machined. The fittings are then polished, laser marked, tested, and packaged before importation into the United States. Based on the manufacturing processes performed in Cambodia, namely threading and/or barbing the ends, this office finds that a substantial transformation has not taken place. It is the opinion of this office that at the time of importation into Cambodia, the fittings are incomplete unfinished articles that have the essential character of the finished articles (fittings). As such, the country of origin for duty purposes and for the purposes of the applicability of trade remedies of the stainless steel PEX fittings is China. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. 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 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, contact National Import Specialist Neil M. Cohen at neil.cohen@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division