CBP Ruling N361492 — The country of origin of valve caps

Tariff classification

HTS codes: 2026, 1201, 1992, 1993, 2018, 1982

Headings: 2026, 1201, 1992, 1993, 2018, 1982

Product description

Item numbers SP005, SP017 and SP012 are referred to as plastic valve caps. The valve stem caps aredome-shaped and threaded to be used on tire valves.With respect to origin, the manufacturing process begins by subjecting raw polypropylene material fromChina to an injection molding process. The resulting product then undergoes trimming and a sorting processin Malaysia. For item number SP012, an O-ring from Malaysia is installed onto the cap. Lastly, each valvecap is inspected and packaged.When determining the country of origin for purposes of applying current trade remedies under Section 301and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters RulingLetter H301619, dated November 6, 2018. The test for determining whether a substantial transformation willoccur is whether an article emerges from a process with a new name, character, or use different from thatpossessed 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 instance, raw material from China is molded and trimmed in Malaysia to form each valve cap. It issubsequent to the processes that occur in Malaysia that the raw material is substantially transformed, and theAccordingly, the country of origin for thv .end use is determined. e subject alve capsisMalaysiaThe holding set forth above applies only to the specific factual situation and merchandise description asidentified in

CBP rationale

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.

Full text

N361492May 27, 2026OT:RR:NC:N1:102
CATEGORY: OriginFangyi TianAutowin Group LimitedFlat/Rm 08, 15/FWitty Commercial Building1A-1L Tung Choi StreetMongkok, Kowloon, Hong Kong ChinaRE: The country of origin of valve capsDear Ms. Tian:In your letter dated
May 13, 2026
, you requested a country of origin ruling on valve caps.Item numbers SP005, SP017 and SP012 are referred to as plastic valve caps. The valve stem caps aredome-shaped and threaded to be used on tire valves.With respect to origin, the manufacturing process begins by subjecting raw polypropylene material fromChina to an injection molding process. The resulting product then undergoes trimming and a sorting processin Malaysia. For item number SP012, an O-ring from Malaysia is installed onto the cap. Lastly, each valvecap is inspected and packaged.When determining the country of origin for purposes of applying current trade remedies under Section 301and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters RulingLetter H301619, dated November 6, 2018. The test for determining whether a substantial transformation willoccur is whether an article emerges from a process with a new name, character, or use different from thatpossessed 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 instance, raw material from China is molded and trimmed in Malaysia to form each valve cap. It issubsequent to the processes that occur in Malaysia that the raw material is substantially transformed, and theAccordingly, the country of origin for thv .end use is determined. e subject alve capsisMalaysiaThe 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 Sandra Martinez at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division

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