The country of origin of aluminum mop poles

N350342
July 1, 2025
OT:RR:NC:N1:164
CATEGORY: Origin Selina Xu Aquastar Inc. DBA Concept Manufacturing 13417 Benson Ave. Chino, CA 91710 RE: The country of origin of aluminum mop poles Dear Ms. Xu: In your letter dated June 18, 2025, you requested a country of origin ruling on aluminum mop poles. The items under consideration are described as two-piece aluminum mop poles which are an assembly of two machined aluminum pipe profiles and various injection molded plastic components. Manufacturing begins in China where plastic pellets are combined with coloring, mixed, and injection-molded to form various plastic parts, such as handle surfaces and parts for connection to other objects. In Vietnam, aluminum pipe profiles from Vietnam are cut according to specifications to form the inner and outer poles. After cutting to length, a groove is clamped on the outer pole by a channeling machine. Following that, the inner pole is chamfered by a chamfering machine and processed by a dotting machine to create a clamping joint. At that point, a punching machine forces one of the plastic parts into one end of the inner pole where it is held in place. Finally, the poles are assembled with the remaining plastic parts and packaged for export. 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). In this case, the aluminum profiles from Vietnam provide the core functionality of the finished aluminum mop poles because they are the rigid structural component that enables a user to efficiently manipulate a mop during use. Although the finished mop poles feature injection-molded plastic components from China, they are primarily supportive, less-significant components which are subservient to the role of the aluminum profiles. In totality, when the functionally predominant aluminum profiles from Vietnam are assembled with the less-significant plastic components from China, they are not substantially transformed. Accordingly, the country of origin of the aluminum mop poles will be Vietnam.

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 (C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
(for) James Forkan Acting Director National Commodity Specialist Division