RE: The country of origin of an air pressure regulator

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365607 October 20, 2026 OT:RR:NC:N1:102 CATEGORY: Origin Icey Huang 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 air pressure regulator Dear Ms. Huang: In your letter dated October 1, 2026, you requested a country of origin ruling on an air pressure regulator. Item number 1111200197 is identified as a 1/4-IN Compressed Air Pressure Regulator. The regulator consists of a pressure gauge positioned in front of valve that is actuated using a knob assembly. The valve consists of a die-cast aluminum valve body with 1/4" NPT female inlet and outlet ports that incorporate a diaphragm assembly, a brass valve spool, springs, an O-ring, an aluminum plug, a valve seat, screws and a bolt. Once connected to a compressed air system, the regulator functions as a valve that stabilizes incoming air pressure to an adjustable constant output pressure for downstream pneumatic tools and equipment. With respect to origin, the final assembly of the regulator occurs in Malaysia using components from China and Malaysia. Prior to the final assembly, the valve body and plug are manufactured in China and exported to Malaysia to undergo a machining process to add threading. Less than three percent of material is removed during the machining process. The final assembly process begins by inserting a screw, a Chinese spring, and a Chinese diaphragm assembly onto a Chinese knob assembly. Afterwards, a valve body is screwed onto the knob assembly. Subsequently, a spool, a spring, an O-ring and plug are manually inserted into the valve body. A Chinese pressure gauge is then screwed onto the valve body. Once complete, the regulator is tested, inspected and packaged ready for shipment. 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). When determining the country of origin of valves, CBP has relied on the origin of the valve body, the essential component of a valve, as the process of assembling a valve is rather simple. Components are typically assembled into the valve body using processes such as inserting and screwing components to each other. Such processes are not regarded as being complex. See New York rulings N339513 (dated May 6, 2024), N338713 (dated April 3, 2024), N325765 (dated May 26, 2022) and N322652 (dated December 2, 2021). The same origin rationale is applicable here, as the assembly processes of the subject regulator, which functions as a valve, primarily consist of inserting components into a valve body. With regard to the origin of the valve body, it is visibly recognizable as a valve body once exported from China. The machining that occurs in Malaysia is minimal and does not substantially transform the valve body into a new and different article of commerce with a name, character, and use distinct from the valve body exported from China. Therefore, as the country of origin of the valve body is China, the country of origin of the air pressure regulator will be China. 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