CBP Ruling N361523 — The country of origin of inflation needles

Tariff classification

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

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

Product description

Technicalinformation was submitted with your request.The item under consideration a inflation needle, Product # SP011, fittingused airsreswhich are s with anpump to inflate or deflate articles with needle valves such as sports balls. asystem Each needle featuresstainless steel needle, a thin tube 1.85 millimeters (mm) thick, and a cylindrical brass head 7.70 mmwhich is in diameter. When assembled, the needle and the head are attached to each other with an internal continuousThe head is externally threaded so it can be pump mechanism, the needleopening. torqued into the while has to airflow between the pump and the inflatable article. a small opening near the tipallow In your submission, you provided a description of the production process.The needles are made of stainless steel tubes that are drawn in China and shipped to Malaysia where they are cut to their final size and crimped.The heads are made from brass originating from Malaysia and machined toto create the opening near the tip their final size and shape using a lathing process in the same country.the needles and heads are At this point combined, creating the inflation needles undergo electroplatingresult in the final product .Finally they, ings.then packed and shipped to the United States.The inflation needles are When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,Headquarters Ruling Letter (HQ) H301619, dated November 6, 2018. The test for determining whether asubstantial 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). The manufacturing processes for the inflation needle, Product # SP011, take p

CBP rationale

substantial transformation analysis is applicable. See, e.g.,Headquarters Ruling Letter (HQ) H301619, dated November 6, 2018. The test for determining whether asubstantial 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). The manufacturing processes for the inflation needle, Product # SP011, take place in two countries Chinases,and Malayasia.A new article does not emerge until the needle and the head are combined. The tubes that are made in China are not yet cut or crimped to resemble the fitting or function as the finished product.It is not until both the needle and head are combined in where the final product is assembled and canMalaysiafunction as a fitting for inflation. Accordingly, the country of origin the inflation needle is Malaysia. of s 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.

Full text

N361523May 27, 2026OT:RR:NC:N1:113
CATEGORY: OriginFangyi TianAutowin Group LimitedFlat/Room 08, 15/FWitty Commercial Building1A-1L Tung Choi StreetMongkok, Kowloon, Hong KongChinaRE: The country of origin of inflation needlesDear Fangyi Tian:In your letter dated
May 14, 2026
, you requested a country of origin ruling on inflation needles. Technicalinformation was submitted with your request.The item under consideration a inflation needle, Product # SP011, fittingused airsreswhich are s with anpump to inflate or deflate articles with needle valves such as sports balls. asystem Each needle featuresstainless steel needle, a thin tube 1.85 millimeters (mm) thick, and a cylindrical brass head 7.70 mmwhich is in diameter. When assembled, the needle and the head are attached to each other with an internal continuousThe head is externally threaded so it can be pump mechanism, the needleopening. torqued into the while has to airflow between the pump and the inflatable article. a small opening near the tipallow In your submission, you provided a description of the production process.The needles are made of stainless steel tubes that are drawn in China and shipped to Malaysia where they are cut to their final size and crimped.The heads are made from brass originating from Malaysia and machined toto create the opening near the tip their final size and shape using a lathing process in the same country.the needles and heads are At this point combined, creating the inflation needles undergo electroplatingresult in the final product .Finally they, ings.then packed and shipped to the United States.The inflation needles are When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,Headquarters Ruling Letter (HQ) H301619, dated November 6, 2018. The test for determining whether asubstantial 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).
The manufacturing processes for the inflation needle, Product # SP011, take place in two countries Chinases,and Malayasia.A new article does not emerge until the needle and the head are combined. The tubes that are made in China are not yet cut or crimped to resemble the fitting or function as the finished product.It is not until both the needle and head are combined in where the final product is assembled and canMalaysiafunction as a fitting for inflation. Accordingly, the country of origin the inflation needle is Malaysia. of s 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 Matthew Gay at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division

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