RE: The country of origin of an expandable water hose

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 N364229 September 2, 2026 OT:RR:NC:N5:137 CATEGORY: Origin Gillian Wilson AN Deringer 173 West Service Rd Champlain, NY 48111 RE: The country of origin of an expandable water hose Dear Ms. Wilson: In your letter dated August 12, 2026, you requested a country of origin ruling on an expandable water hose on behalf of your client, Meridian International Co. Ltd. The product under consideration, an expandable hose, is a flexible water hose, constructed with an elastic inner tube and a protective outer covering. The hose expands in length when filled with water under pressure and contracts when the water is drained. The hose will be imported in lengths of 25, 50 and 100 feet. The hose under review undergoes two manufacturing phases. The first manufacturing phase takes place in Vietnam. Thermoplastic elastomer and latex raw materials are extruded to form the expandable hose’s inner tube. The inner tube is shipped on rolls to China for further processing. The second manufacturing phase takes place in China. Polyester yarn is woven on an automatic braiding machine to produce the textile fabric sleeve that surrounds and protects the inner tube. Aluminum raw material is cut and machined using CNC turning operations to produce the fittings and clamp components used in the hose assembly. Thermoplastic rubber is injection molded to produce the grip and washer components for the hose end fittings. The Vietnamese origin inner tube is cut to the desired length and combined with the Chinese origin braided fabric, fittings, clamps, washers, and grips. 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).
In this case, the reinforcement with braided materials, cutting to length, and the addition of the Chinese fittings does not substantially transform the hose. Therefore, the country of origin of the finished hose with fittings is considered to be Vietnam. 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 Christina Allen at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division