The country of origin of a tube assembly

N361172May 18, 2026OT:RR:NC:N2:206
CATEGORY: OriginHyung Chan KimDAOU PrecisionNoksansaneopjung-ro, Gangseo-guBusan 46752South KoreaRE: The country of origin of a tube assemblyDear Mr. Kim:In your letter dated
April 30, 2026
, you requested a country of origin ruling on a tube assembly.The item under consideration is an automotive tube assembly, Part Number 22340-JY00A, which you refer toas a Tube Assy Pres Sens Inlet or as a pipe. You state that the assembly is a circulation channel of theexhaust gas from the catalytic converter to the pressure sensor. It is located on the exterior of the catalyticconverter and carries purified exhaust gas. The tube is bent to a specific configuration and contains a bracketand a flare nut.According to your submission, a straight pipe of Vietnamese origin, and a flare nut of Chinese origin areimported into Korea for further manufacturing and assembly with a Korean origin bracket. In Korea, the pipeundergoes inserting, flare nut inserting, forming, auto bending, bracket inserting, leak testing, drying, finalinspection, packaging, and shipping.Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, everyarticle of foreign origin imported into the United States shall be marked in a conspicuous place as legibly,indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as toindicate to the ultimate purchaser in the United States, the English name of the country of origin of thearticle. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able toknow by an inspection of the marking on the imported goods the country of which the goods is the product.The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, byknowing where the goods were produced, be able to buy or refuse to buy them, if such marking shouldinfluence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940).Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements thecountry of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBPRegulations (19 CFR 134.1(b)), defines “country of origin” 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 articlein another country must effect a substantial transformation in order to render such other country the “countryof origin” within the meaning of the marking laws and regulations.A substantial transformation occurs when, as a result of manufacturing process, a new and different articleemerges, having a distinct name, character or use, which is different from that originally possessed by thearticle or material before being subjected to the manufacturing process. See United States v.Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940).In the present case, the straight pipe from Vietnam is substantially transformed from a pipe into anidentifiable automotive component in Korea when it is expanded and bent into a specific configuration. Therest of the components, the flare nut and bracket, lose their individual identities when secured to the pipe, andbecome parts of the tube assembly. As a result, a substantial transformation occurs in Korea. Therefore, thecountry of origin of the automotive tube assembly, Part Number 22340-JY00A, will be South Korea formarking purposes.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Liana Alvarez at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division