RE: Country of Origin of a Centrifugal Pump

HQ H361100 September 23, 2026 OT:RR:CTF:VS H361100 RRB CATEGORY: Origin Deborah Stern Sandler, Travis & Rosenberg, P.A. 5835 Waterford District Drive, Suite 200 Miami, FL 33126 RE: Country of Origin of a Centrifugal Pump Dear Ms. Stern: This is in response to your request, dated May 29, 2026, filed on behalf of your client, ITT Goulds Pumps Inc. (“GP”), regarding the country of origin of a centrifugal pump. You have requested that certain information submitted in connection with this ruling request be treated as confidential. Inasmuch as the amended scope of your confidentiality request conforms to the requirements of 19 C.F.R. § 177.2(b)(7), the request for confidentiality is approved. The information contained within brackets will not be released to the public and will be withheld from published versions of this decision. FACTS: ITT Goulds Pumps Inc. (“GP”) designs, manufactures, and imports mechanical pumps to serve customers in the energy, mining, power, chemical, pulp and paper, water and wastewater, and general industrial markets. The pump that is the subject of this ruling request is GP’s model 3600 centrifugal pump (“Centrifugal Pump”), which is described as an axially-split, multi-stage, between-bearings centrifugal pump with motor. It is intended for use in refineries, injection offshore platforms, remote pipelines, boiler feed in mid-range cogeneration, descaling, mine dewatering, process transfer, desalination, and CO2 injection.
A centrifugal pump works by converting rotational energy into hydrodynamic energy of a fluid flow when fluid enters the pump impeller near the rotating axis and is accelerated by the impeller. You explain that because the basic principle of a centrifugal pump’s operation is the conversion of rotational energy into hydrodynamic energy, the essential component of the Centrifugal Pump is its source of rotational energy, i.e., the motor. You state that the Centrifugal Pump’s main components are the motor, 6 or 8 impellers, casing/housing, stuffing box, shaft, and base plate (bed plate). The Centrifugal Pump also consists of minor parts such as seals, screws, and other fasteners. Each of these components is sourced by GP from third-party suppliers for final assembly by GP at its manufacturing facility in Brazil. You assert that the motor is purchased in its complete form and fully assembled from a third-party supplier. You further state that the country of origin of the motor is the United States. The motor is manufactured in the United States with rotors and stators that are also manufactured in the United States. In support, you provided a signed statement of origin from the third-party supplier, certifying that as of April 16, 2026, the country of origin for the motors identified by part number [**-****] and part number [**- ****] and their corresponding stators and rotors were manufactured in the United States. You also provided a costed bill of materials (“BOM”), which notes that the motor was sourced from the United States. In addition to sourcing the motor, the BOM identifies the various countries from which other components of the Centrifugal Pump will be sourced, including India, Korea, Mexico, and China. In addition to the costed BOM and signed statement of origin for the motor component, you provided various confidential exhibits detailing the assembly process for manufacturing the Centrifugal Pump. These consist of the following: • Specifications and photos of the finished centrifugal pump • Cutaway drawing of a portion of the pump without the third-party motor • Work instructions for the pump detailing the components and assembly process, including graphical images and references to the personnel employed in the process • Work instructions for the bed plating process, including mounting the pump and motor to the bed plate • Quality control procedure for mounting and aligning the motor to the pump and bed plate • Specifications and photos of the motor from the third-party supplier Although GP does not manufacture the motor, you provided information from the U.S. motor supplier detailing the manufacturing steps for that component. The manufacturing processes for the motor subassembly, pump subassembly, and bed plating process are described in more detail below. 2
Motor assembly in the United States According to information provided by the third-party motor supplier, the motor is produced in the United States under the following steps: cutting, punching and stacking of the laminations for stator and rotor cores; pressing and heating of cores into solid cores; making of winding coils and hand winding into the core; vacuum pressure impregnation (VPI) treatment and core winding/testing; machining of shaft and heat treatment; pressing shaft into rotor core; balancing and installation of external fans; machining of brackets and frames; assembly of terminal boxes and auxiliary boxes with internal connections; pressing of winding into frame and rotor insertion; final assembly of all parts and connections; and routine testing. As referenced above, the third-party supplier affirmed via signed statement that the stators and rotors are manufactured in the United States, where the motors are also manufactured. The third-party supplier further states that it expends 71-78 hours to produce the motor in the United States. Moreover, as illustrated by the costed BOM, the cost of the motor is more than half the cost of the finished pump. Assembly operations in Brazil As supported by the confidential exhibits that you provided in support of this request, you set forth a summary of the assembly steps for the Centrifugal Pump in Brazil, along with instructions for the bed plating process, which includes mounting the pump and motor to the bed plate. According to the work instructions for the assembly of the Centrifugal Pump, foreign-sourced components are fitted together and aligned in a series of 45 steps, which total 21 hours of assembly in Brazil. The work instructions for the bed plating process reflect an additional 2.5 hours of assembly encompassed within nine additional steps. The steps from both phases of the total assembly include operations such as assembling and balancing the impellers onto the shaft in a press- fitting process; assembling the rotor inside the casing through insertion and positioning of internal components that are bolted and torqued; installing the mechanical seals onto the shaft through bolting and torquing; assembling the bearings and bearing housings by installing, aligning, doweling, and machining of spacers for correct centering; operational/performance testing whereby the pump is coupled to the electric motor and run to verify performance requirements; final assembly of the pump, base, and motor by closing the casing with a gasket and through controlled bolting/torquing, installing seals/bearings/housings, and performing alignment verification. These steps are followed by packaging of the finished Centrifugal Pump. ISSUE: What is the country of origin of the Centrifugal Pump for duty purposes? LAW AND ANALYSIS: When determining the country of origin for purposes of applying trade remedies under Section 301, the substantial transformation analysis is applicable. The test for 3
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 (CCPA 1982). In deciding whether the combining of parts or materials constitutes a substantial transformation, the determinative issue is the extent of operations performed and whether the parts lose their identity and become an integral part of the new article. See Belcrest Linens v. United States, 6 CIT 204, 573 F. Supp. 1149 (1983), aff’d, 741 F.2d 1368 (Fed. Cir. 1984). Assembly operations that are minimal or simple, as opposed to complex or meaningful, will generally not result in a substantial transformation. Factors which may be relevant in this evaluation include the nature of the operation (including the number of components assembled); the number of different operations involved; and whether a significant period of time, skill, detail, and quality control are necessary for the assembly operation. See C.S.D. 80-111, C.S.D. 85- 25, C.S.D. 89-110, C.S.D. 89-118, C.S.D. 90-51, and C.S.D. 90-97. If the manufacturing or combining process is a minor one which leaves the identity of the article intact, a substantial transformation has not occurred. See Uniroyal, Inc. v. United States, 3 CIT 220, 542 F. Supp. 1026 (1982), aff’d, 702 F.2d 1022 (Fed. Cir. 1983). The Court of International Trade more recently interpreted the meaning of “substantial transformation” in Energizer Battery, Inc. v. United States, 190 F. Supp. 3d 1308 (CIT 2016). Energizer Battery involved the determination of the country of origin of a flashlight, referred to as the Generation II flashlight. All of the components of the flashlight were of Chinese origin, except for a white LED and a hydrogen getter. The components were imported into the United States and assembled into the finished Generation II flashlight. The Energizer Battery court reviewed the “name, character and use” test utilized in determining whether a substantial transformation had occurred and noted, citing Uniroyal, Inc., 3 C.I.T. 220, 226, 542 F. Supp. 1026 (1982), aff’d per curiam, 702 F.2d 1022 (Fed. Cir. 1983), that when “the post-importation processing consists of assembly, courts have been reluctant to find a change in character, particularly when the imported articles do not undergo a physical change.” Energizer Battery at 1318. In addition, the court noted that “when the end-use was pre- determined at the time of importation, courts have generally not found a change in use.” Energizer Battery at 1319, citing as an example, National Hand Tool Corp. v. United States, 16 C.I.T. 308, 312 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). Historically, CBP has concluded that press-fitting or connecting fan or pump components to a motor does not result in a substantial transformation when considering the country of origin of a fan or pump assembly. See Headquarters Ruling Letter (“HQ”) H313089, dated February 16, 2021. In examining assembly operations, CBP has looked to the nature of the assembly, as well as the origin of the component that imparts the “essential character” to the end product. Id. In fan or pump assembly cases, CBP has found that the motor imparts the essence of these types of assemblies. See HQ H303864, dated December 26, 2019. Further, it is generally CBP’s position that the country of origin of a motor will be determined by where the essential components of that motor are made. See New York Ruling Letter (“NY”) N305251, dated August 1, 2019. However, whether an assembly process is sufficiently complex to rise to the level 4
of a substantial transformation is determined upon consideration of all of the operations that occur in a particular country, including any subassembly processes that take place in that country. For example, in HQ H303866, dated February 13, 2020, CBP considered the country of origin of automobile windshield washer pumps. There, approximately half of the discrete parts were shipped to Mexico to be combined with components from Mexico to form subassemblies. These subassemblies were combined to create a motor assembly in Mexico. The processing of the subassemblies that comprised the finished pump assembly was complex and involved soldering, fusing, machining, plastic injection molding, and crimping, as well as press-fitting. Accordingly, CBP found that the discrete parts were substantially transformed when combined to form a finished centrifugal pump in Mexico. By contrast, assembly operations that are minimal or simple, and incorporate components with a pre-determined end-use will generally not result in a substantial transformation. In HQ H303864, dated December 26, 2019, the assembly of a Chinese motor with an impeller, a seal, and a plastic housing to form a finished pump assembly in Mexico did not result in a substantial transformation because the assembly involved press-fitting the parts into each other. Similarly, in HQ H302821, dated July 26, 2019, the assembly of five subassemblies and other components from China with a pre- determined end-use into passenger vehicles in Sweden was not complex and the individual components did not undergo a change in use. In NY N314774, dated October 23, 2020, CBP examined the country of origin of a submersible pump assembled in China from various components, including a Vietnamese motor that represented more than 50% of the value of the finished pump assembly. The Vietnamese motor was shipped to China for assembly with the Chinese impeller, the U.S.-origin shaft seal, the Chinese plastic housing, the volute, and the cover to form the finished pump assembly by press-fitting the components to each other. CBP noted that press-fitting is considered a simple assembly and the electric motor did not undergo further operations other than simple assembly in China. Accordingly, because no substantial transformation occurred as a result of the assembly operations in China, and where the electric motor imparted the very essence of the pump assembly, CBP held that the country of origin of the submersible pump in NY N314744 was Vietnam. In the instant case, an electric motor of U.S.-origin—produced in the United States from a stator and rotors that are also manufactured in the United States—is shipped to Brazil for assembly with the 6-8 impellers, casing/housing, stuffing box, shaft, and bed plate, which are sourced from various countries. As in NY N314744, the cost of the U.S.-origin motor in the instant matter is more than half the cost of the finished Centrifugal Pump. Likewise, assembly of the various components by press-fitting with each other, aligning, balancing, simple machining, and fastening is rather simple. As we have held in HQ H303864, HQ H302821, and NY N314744, these types of simple assembly operations when manufacturing a pump assembly do not result in a substantial transformation of the component parts. Accordingly, we find that the assembly of the various foreign-sourced components with the U.S-origin motor does not result in a substantial transformation of the components when assembled into a centrifugal pump in Brazil. Moreover, where the U.S-origin motor is the most expensive 5
component and substantive part of the finished Centrifugal Pump and imparts its identity and functionality, we find that the country of origin of the finished Centrifugal Pump will be the same as the motor component, i.e., the United States. HOLDING: The country of origin of the Centrifugal Pump for duty purposes will be the United States. Please note that 19 C.F.R. § 177.9(b)(1) provides that “[e]ach ruling letter is issued on the assumption that all of the information furnished in connection with the ruling request and incorporated in the ruling letter, either directly, by reference, or by implication, is accurate and complete in every material respect. The application of a ruling letter by [CBP] field office to the transaction to which it is purported to relate is subject to the verification of the facts incorporated in the ruling letter, a comparison of the transaction described therein to the actual transaction, and the satisfaction of any conditions on which the ruling was based.” A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is entered. If the documents have been filed without a copy, this ruling should be brought to the attention of the CBP officer handling the transaction. Sincerely, Monika R. Brenner, Chief Valuation and Special Programs Branch 6