The country of origin of a retractable hose reel with hose

N363610 August 3, 2026 OT:RR:NC:N5:137 CATEGORY: Origin Felix Zhang Maxforce Tools (Cambodia) Co., Ltd. Building D61-4, Sihanoukville Special Economic Zone, Sihanoukville 180100 Cambodia RE: The country of origin of a retractable hose reel with hose Dear Mr. Zhang: In your letter dated July 24, 2026, you requested a country of origin ruling on a retractable hose reel with hose. Item Numbers 821-1359 and 821-1360 are 50-foot single-arm retractable air hose reels. Item 821-1359 consists of a 3/8” by 50-foot air hose and reel, while item 821-1360 consists of a ½ inch by 50-foot air hose and a reel. The reel is made of steel and includes a spring-loaded auto-rewind reel mechanism, while the hose is constructed predominantly of polyvinyl chloride (PVC) plastic reinforced with braided polyester and features male brass fittings at both ends. The hoses serve to deliver pressurized air from an air compressor to pneumatic hand tools while the reels, which can be mounted to a wall or ceiling, provide storage for the hose. Hose manufacturing steps: The Chinese origin raw materials are placed into a machine to uniformly mix the raw materials and create uniform mixture suitable for extrusion. The mixture is fed into an extrusion line where it is heated and forced through a die to produce the inner hose to a specific diameter and wall thickness. The hose then passes through a winding machine where it is reinforced with polyester. Additional mixture is fed into an extrusion line where it is heated and forced through a die to create the hose’s outer cover. The fully formed hose passes through a printing station to be labeled with name, specifications and compliance markings. The hoses are cut into 50-foot lengths. Cut hoses are fed into a coiling machine that rolls them into compact, uniform coils. Brass fittings are attached to the ends of the hose. The fittings are inserted and then secured using a crimping machine. Steel hose reel manufacturing steps: The Chinese origin steel plates are fed into a cutting machine to be sliced into precise dimensions for components. The plates are processed through various metal working machines to punch, stamp and bend them into the right-angle base plate, right angle tension spring mounting bracket, support arm and front and back reel pieces. After stamping, all steel parts are sent to the powder coating area for surface finishing. Hose reel assembly steps: The hose reel spool, which will hold the hose, is assembled together with fasteners. The structural components of the support-arm, base plate, and tension spring mounting bracket are assembled together to form the frame that supports the spool and allows it to rotate. Bolts and screws are used to fasten the components together. The spring mechanism, of Chinese origin, will enable automatic hose retraction. It is assembled into its protective case. The pre-assembled case is installed onto the reel, connecting the spring to the reel’s internal mechanism to allow it to retract the hose when released. The hose is rolled into the reel. All of the external components are attached to produce the final body assembly. 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. It is the opinion of this office that the manufacturing operations conducted in Cambodia result in a substantial transformation. Therefore, the country-of-origin of the retractable hose reel with hose will be Cambodia. 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 Christina Allen at julie.c.allen@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division