The country of origin of a ball valve

N358193
February 11, 2026
OT:RR:NC:N1:102
CATEGORY: Origin Stephen Fodor Customs Services & Solutions Inc 6576 Church Street Douglasville, GA 30134 RE: The country of origin of a ball valve Dear Mr. Fodor: In your letter dated January 18, 2026, you requested a country of origin ruling on behalf of your client, Metalworks Ningbo Aida, Inc, for the purpose of applying trade remedies and additional duties. The item at issue is a ball valve, item number XYEPBV33. The valve is primarily constructed of stainless-steel material and is intended to be used in water lines of domestic settings. It is noted that you also inquired about the country of origin of fittings. Please note the fittings will be addressed in ruling N357926. With respect to origin, you explain the ball valve will be assembled in Cambodia using components sourced from China. Prior to the final assembly, the exterior of the endcap and the valve body will undergo a machining process in Cambodia. The machining process will produce barbs, which is a feature that creates a secure and leak-resistant connection when the valve is installed. The final assembly of the ball valve will begin by press fitting a stem, a ball seat and a ball into a valve body. The ball seat will then be pressed into an endcap. Next, glue will be placed on the threads of the endcap, and the endcap will subsequently be fastened to the valve body using screws. Lastly, a handle will be placed over the stem and fastened in place using a nut. Once the assembly process is complete, the finished ball valve will be tested, laser marked and packaged ready for retail sale. 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 a valve, 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 a valve body by inserting, pressing and screwing components to each other. 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. Therefore, as the processes described above do not result in a substantial transformation, we rely on the origin of the valve body to determine the origin of the ball valve. In the scenario above, the valve body will be sourced from China and subsequently machined in Cambodia. The machining process adds barbs to the valve body, allowing the valve to interface with tubes in a secure manner. In viewing the illustrations provided in your submission, the valve body clearly has a pre-determined end use prior to the machining process in Cambodia. The valve body is configured as a housing designed to incorporate a ball and other integral component parts. The machining process does not substantially transform the valve body into a new and different article of commerce with a name, character, or 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 ball valve will be China at the time of importation. 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 [email protected].
Sincerely,
(for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division