The country of origin of insulated copper tubing
Issued April 21, 2017 by U.S. Customs and Border Protection.
Tariff classification
HTS codes: 2017
Headings: 2017
Product description
The country of origin of insulated copper tubing
CBP rationale
substantial transformation in order to render such other country the 'country of origin' within the meaning of this part. With respect to the insulated copper tubing, fitting the two components together, cutting to length and coiling the tubing does not result in a new product having a distinctive name, character or use. Therefore, in our opinion, the good remains a product of South Korea.
Full text
N284627 April 21, 2017 MAR-2 OT:RR:NC:N1:117 CATEGORY: Country of Origin Mr. Craig K. Hickam Toll Global Forwarding (USA) Inc. 150-15 183rd Street Springfield Gardens, NY 11413 RE: The country of origin of insulated copper tubing Dear Mr. Hickam: This is in response to your undated letter received by our office on March 22, 2017, on behalf of Icool USA Incorporated, requesting a ruling on the country of origin of insulated copper tubing assembled in China. A representative sample was included with your request and will be returned to you. The item in question is insulated copper tubing used in the automobile industry for air conditioning units. You indicate that copper tubing, produced in South Korea, will be shipped to China where it will be inserted through a polyethylene (PE) insulation tube of Chinese origin. The copper tubing is then cut to a specific length, coiled and packed in a cardboard box before being imported. The "country of origin" is defined in 19 CFR 134.1(b) 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 this part. With respect to the insulated copper tubing, fitting the two components together, cutting to length and coiling the tubing does not result in a new product having a distinctive name, character or use. Therefore, in our opinion, the good remains a product of South Korea. 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 Mary Ellen Laker at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division
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HTSUS ear Mr. Shoichet D his is in response to your request of March 15, 2023, on behalf of your client, [ T ] (the “requestor”). In your letter, you request a ruling pursuant to 19 CFR Part 177 concerning the valuation of watches and watch components imported by your client. Your client has asked that certain information submitted in connection with this internal advice request be treated as confidential. Inasmuch as this request conforms to the requirements of 19 C.F.R. § 177.2(b)(7), your client’s request for confidentiality is approved. The information contained within brackets as well as all documents forwarded to our office will not be released to the public and will be withheld from the published version of this decision. FACTS The following information is based on your March 15, 2023, ruling request and follow-up information provided to this office on October 2, 2023, November 14, 2023, and July 12, 2024. The requestor is an importer and distributor of watches containing both S
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