The country of origin of a pressure reducing valve

N363286August 11, 2026OT:RR:NC:N1:102
CATEGORY: OriginKaria HerreraRL Jones CHB1610 Landmark RoadSan Diego, CA 92154RE: The country of origin of a pressure reducing valveDear Ms. Herrera:In your letter dated
July 13, 2026
, you requested a country of origin ruling on behalf of your client, AcornEngineering Company Inc.Item number YRV03P0-6 is referred to as a pressure-reducing valve. The automatic valve adjusts flow andpressure based on its settings. The valve is designed to reduce the incoming water pressure, minimizing thepotential for leaks and downstream water consumption.With respect to origin, the final assembly occurs in Taiwan using components from Taiwan and othercountries.The final assembly begins by disc into the bodyinserting a , a disc holder, and a washer seat followed by theinsertion of a top and bottom stem. Next, a diaphragm from the United States and a diaphragm cup are oilednstall and iedinside the body seat followed by the insertion of a screen to complete the cartridge assembly. from Afterwards, astrainer bonnet China, along with a plug is manually screwed onto the valve body fromChina. The finished valve is then tested and packaged ready for shipment.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).When determining the country of origin of valves, has relied onU.S. Customs and Border Protection (CBP)the origin of the valve body, the essential component of a valve, as the process of assembling a valve is rathersimple. Components are typically assembled into the valve body using processes such as inserting and
screwing components to each other. Such processes are not regarded as being complex. See New Yorkrulings N339513 (dated May 6, 2024), N338713 (dated April 3, 2024), N325765 (dated May 26, 2022) andN322652 (dated December 2, 2021). The same origin rationale is applicable here, as the assembly processesof the subject valve primarily consist of inserting placingcomponents to each other.and With regard to the origin of the valve body, it is not until the machining and finishing processes, which occurin , that the casting is recognizable as a valve body. It is in that the features of the valve body areChinaChinaformed, substantially transforming the casting into a new and different article of commerce with a name,character, and use distinct from the casting exported from China. As such, the county of origin for the is .pressure reducing valveChinaThe 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 CBP and submit arequest for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material factsdescribed 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 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