The country of origin of a hose reel system

N356042
November 20, 2025
OT:RR:NC:N5:137
CATEGORY: Origin Kevin Doucette CH Robinson International. Inc. 14701 Charlson Rd Eden Prairie, MN 55347 RE: The country of origin of a hose reel system Dear Mr. Doucette: In your letter dated November 14, 2025, you requested a country of origin ruling on a hose reel system. The products under consideration are SKU#’s 83753 and 83754. They are described as steel hose reels incorporating plastic hoses. The hoses are constructed of a predominantly plastic mixture containing some nitrile rubber. Each unit consists of either a 3/8-inch or ½-inch air hose mounted on an automatic steel rewind reel. These assemblies are commonly used in vehicle maintenance and industrial facilities for delivering pressurized air to tools and equipment. The reels and the hoses are manufactured in Cambodia from Chinese origin raw materials and hardware according to the following steps: Hose manufacturing steps: The Chinese origin raw materials are placed into a granule producing machine to uniformly mix the raw materials and create uniform granules suitable for extrusion. The mixed granules are fed into an extrusion line where it is heated and forced through a die to produce the hose to a specific diameter and wall thickness. The hose then passes through a winding machine where it is reinforced with polyester. Mixed granules are fed into an extrusion line where they will be 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. Cut hoses are fed into a coiling machine that rolls them into compact, uniform coils. After coiling is completed, the hose is stored until the hose reel assembly process.

Steel hose reel manufacturing steps: Small steel plates are fed into a cutting machine to be sliced into precise dimensions for components (arms and axis). Large steel plates are processed using a heavy-duty cutting machine to create a steel blank to be used in the stamping process. Steel plates designated for the hose reel spool are shaped into a cylindrical form using a curling machine. Steel components for the reel’s arms and base are bent into their final shapes using a bending machine. A stamping machine is used to press steel plates into specific reel shapes finalizing the mechanical form of the reel components. After stamping, all steel parts are sent to the powder coating area for surface finishing. All stamped and shaped steel parts are thoroughly cleaned to remove dirt, oil residue and metal shavings. Cleaned parts are hung to allow full exposure of all surfaces during coating and curing. Powder coating, sourced from China, is applied using an electrostatic spray gun creating a durable, corrosion-resistant and aesthetically pleasing finish. Coated parts are placed in a curing oven where temperatures typically range from 180°C to 200°C (356°F to 392°F). The heat melts and fuses the powder into a smooth, hard coating. After curing, parts are removed from the oven and hung to cool naturally. Once cooled the parts are ready for final assembly into the complete hose reel system Hose reel assembly steps: Brass or steel fittings are attached to the ends of the hose. The fittings are inserted and then secured using a crimping machine. The hose reel spool, which will hold the hose, is assembled together with the ratchet mechanism. The ratchet will allow the hose to be locked into place when pulled out and then to retract smoothly. Fasteners, from China, are tightened with an electric wrench. The structural components of the reel-arm, base, and axis- are assembled together to form the frame that supports the spool and allows it to rotate. The electric wrench is used to fasten bolts and screws, from China. 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 spool, connecting the spring to the spool’s internal mechanism to allow it to retract the hose when released. The hose is rolled into the spool using a winding machine to ensure the hose is evenly and tightly coiled, preventing tangles. The spool, arm and base are aligned and secured with fasteners to ensure that the reel is structurally sound and ready for use. A Chinese origin swivel joint, which allows the hose to rotate without twisting, is installed. All of the external components are attached to produce the final body assembly. The hose reel system is labeled, packaged and palletized for shipping. 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).

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 hose reel system 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 [email protected].
Sincerely,
(for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division