The country of origin of a foot pump

N362171
June 23, 2026
OT:RR:NC:N1:102
CATEGORY: Origin Fangyi Tian Autowin Group Limited Flat/Rm 08, 15/F Witty Commercial Building 1A-1L Tung Choi Street Mongkok, Kowloon, Hong Kong China RE: The country of origin of a foot pump Dear Ms. Tian: In your letter dated June 9, 2026, you requested a country of origin ruling on a foot pump. The item under consideration is a foot pump, SKU number 1687708. The portable inflating device is primarily composed of a frame that incorporates a single-tube barrel and features a foot bracket, a foot cover, a foot sleeve, a rear foot pad, a pressure gauge, a plastic air outlet, an air tube, and a Schrader valve. With respect to origin, the final assembly occurs in Malaysia using components from Malaysia. Certain plastic components (the foot pad, the air outlet, the foot sleeve and the pressure gauge) are produced using an injection molding process in Malaysia with raw material from China. Metal components are all produced in Malaysia using raw material from Malaysia. During the final assembly, the barrel, the frame, the pressure gauge, the valve and other components are manually assembled to each other and secured in position using rivets and screws from Malaysia. The finished pump is then tested 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).

Based upon your description of the manufacturing operations, all of the components of the foot pump, including the plastic components, are manufactured in Malaysia. The plastic components emerge with a new name, character, and use, different from that possessed by the raw material from which they were formed. Subsequent to the manufacturing processes, the components are assembled to each other in Malaysia. Thus, based on the totality of the circumstances, the country of origin of the foot pump will be Malaysia. 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) James P. Forkan Director National Commodity Specialist Division