The country of origin of gate and butterfly valves

N362852
July 29, 2026
OT:RR:NC:N1:102
CATEGORY: Origin Shanshan Liang Liang + Mooney, PLLC 2104 Delta Way, Unit 1 Tallahassee, FL 32303 RE: The country of origin of gate and butterfly valves Dear Ms. Liang: In your letter dated July 3, 2026, you requested a country of origin ruling on behalf of your client, Galaxy Industrial (Thailand) Co., Ltd. The products under consideration are gate valves (ranging from DN50/2" to DN600/24") and butterfly valves (ranging from DN50/2" to DN800/32"). Each butterfly valve consists of a cast iron body, a seat, a valve disc, and a handle for manual actuation. Each gate valve features a cast iron body with flanged ends for pipeline connection, a handwheel for manual actuation, a resilient-seated closure, and a stem. While the valves vary in size, they are all designed to control the flow of fluid. With respect to origin, the final assembly of both types of valves occurs in Thailand using components from China and a valve body from Thailand. Prior to the final assembly, the valve body and other components undergo precision machining to achieve exact dimensions and tolerances. Machining operations include drilling, boring, turning, and milling to ensure a proper fit of the all the components. Afterwards, the valve body is subjected to a surface treatment and a coating process. The final assembly begins by positioning a valve bushing, a rubber seat, a disc and a stem in a valve body in sequence. Additional boring operations are completed to refine the internal dimensions and tolerances necessary to achieve a proper fit of the components. Afterwards, the inserted components are mechanically pressed in place. Once complete, pins are inserted into the assembly to retain the components in their operational positions. Lastly, an actuator is connected and screwed onto the valve. Inspections and testing are completed throughout the assembly process.

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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article 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 to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know 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, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence 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 the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (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 article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. In this instance, the components of both valve types are inserted into a valve body and pressed into place. This process is relatively simple and does not transform the Chinese components into new and different articles of commerce with a name, character, and use different from that possessed prior to the final assembly operations. Because the processes described above do not result in a substantial transformation, we rely on the origin of the valve bodies to determine the origin of the subject valves. Consequently, as the country of origin of the valve bodies for both valve types is Thailand, the country of origin of the butterfly and gate valves will be Thailand. 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