RE: The country of origin of a washer fluid tank assembly

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364147 August 26, 2026 OT:RR:NC:N2:206 CATEGORY: Origin Xiaozhen Qiao Joinhands International (Thailand) Co., Ltd. 538 Moo 6, Makham Khu Subdistrict Nikhom Phatthan District Rayong Provice 21180 Thailand RE: The country of origin of a washer fluid tank assembly Dear Ms. Qiao: In your letter dated August 8, 2026, you requested a country of origin ruling on a washer fluid tank assembly. The article under consideration is a washer fluid tank assembly designed for use in a motor vehicle. The assembly consists of a molded plastic tank body, filer cap, washer pump with rubber gasket, plastic inner fitting, rubber hose, sealing gasket, and liquid level sensor. The tank serves as a reservoir for windshield washer fluid, while the pump delivers the fluid through the vehicle’s washer system and the liquid level sensor monitors the amount of fluid contained within the tank. The washer fluid tank assembly is manufactured in Thailand using components of Thai and Chinese origin. The tank body and the plastic inner fitting are of Thai origin. The washer, pump with rubber gasket, rubber hose, sealing gasket, filler cap, and liquid level sensor are of Chinese origin. In Thailand, the tank body is produced by a blow-molding process and subsequently assembled with the remaining components. During assembly, the following steps are taken: plastic inner fitting tube is fitted to the rubber hose rubber hose is connected to the washer pump sealing gaskets are fitted to the openings of the tank body washer pump is press-fit onto the tank body liquid level sensor is mounted onto tank body and tested 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 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). It has been a long-standing CBP position that simple assembly of components does not result in a substantial transformation. As a result, we must determine the character of the washer fluid tank assembly. Although the tank body is an important component of the finished washer fluid tank assembly, as it serves as the reservoir for the washer fluid, it is the washer pump that imparts the character of the finished article. The pump performs the essential function of moving and dispersing the washer fluid through the vehicle’s washer system to the windshield. Without the pump, the fluid would merely remain stored within the tank and the assembly would be unable to perform its intended function. Moreover, the Chinese-origin pump retains its identity and predetermined use throughout the assembly operations performed in Thailand and is not substantially transformed as a result of those operations. Accordingly, the country of origin of the finished washer fluid tank assembly is China. 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 Liana Alvarez at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division