RE: The country of origin of pressure washer nozzles, foam cannons, and pressure washer guns

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 N364570 September 15, 2026 OT:RR:NC:N1:105 CATEGORY: Origin Sarah Li 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 pressure washer nozzles, foam cannons, and pressure washer guns Dear Ms. Li: In your letter dated August 25, 2026, you requested a country of origin ruling on pressure washer nozzles, foam cannons, and guns. Descriptive literature was provided for our review. The first item under consideration is described as a 5-piece pressure washer nozzle tip set (SKU T03-NK2). The set consists of five color-coded 1/4-inch quick-connect nozzles tips. The tips are used with pressure washer guns to provide multiple spray patterns for different cleaning scenarios. The red has a 0° angle for a concentrated jet, the yellow has a 15° angle for tough grime, the green has a 25° angle for general-purpose use, the white has a 40° angle for vehicles and delicate surfaces, and the black has a 65° angle for low-pressure soap application. Each nozzle tip comprises a plastic cap, a nozzle insert (stainless steel for red, green, yellow, and white tips and no separate insert for the black), and a nozzle body (stainless steel for red, green, yellow and white tips, and brass for the black). The second item under consideration is described as a foam cannon kit (SKU S02-A02K), which is a heavy-duty car wash sprayer designed for high-pressure application. The unit features a side-filling port and an integrated measuring cup, which facilitate precise soap dispensing and mitigate the risk of spillage. The 1-liter reservoir is manufactured with a reinforced, wide-neck design to enhance structural integrity against high-frequency vibrations. The primary assembly consists of an aluminum alloy and stainless-steel nozzle, equipped with a standard 1/4-inch quick-connect fitting. The configuration is said to provide corrosion resistance, adjustable spray patterns, and compatibility with a wide range of pressure washer systems. The third item under consideration is described as the foam cannon kit with soft-grip short pressure washer gun (SKU S02-A02K2). The kit is the same as the second item but also includes a brass adapter and the gun described in item four. The kit is designed for high-pressure cleaning applications, emphasizing compact dimensions and maneuverability. The spray gun features a soft-grip handle engineered to reduce operator
fatigue during prolonged use. The kit includes a solid brass adapter designed to facilitate a secure, leak-resistant connection to standard pressure washer hoses. The short-profile design of the spray gun is intended to enhance control and accessibility in confined areas, such as vehicle wheel wells and engine compartments. The fourth item under consideration is described as a short pressure washer gun with rigid plastic handle (SKU P01-XQ06). The device is manufactured for high-pressure cleaning applications, specifically designed to enhance maneuverability in confined spaces such as wheel wells, undercarriages, and engine compartments. The gun features a rigid, high-impact plastic handle designed for ergonomic use and durability in both professional and residential environments. The internal valve assembly is constructed of solid brass and stainless steel, intended to ensure structural integrity, corrosion resistance, and the reliable management of high-pressure water flow. The nozzle tips, foam cannons and guns are made with components sourced from China and Malaysia. The Chinese components include the stainless-steel (for the nozzle insert, nozzle body, inlet connector, foam generator core, extension tube, valve stem, and valve sleeve), plastic caps, 1-liter bottle, suction tube, adjustment knob, screws, nozzle sleeve pin, foam filter, spray blade holder, spray blades, nozzle housing, O-rings, red side cover, gun housing, trigger safety lock, trigger, valve spring, valve ball, valve seat seal, springs, retaining ring and locking balls. The Malaysian components including the brass bar stock used for the jet nozzle, bottle adapter, main valve body, adjustment valve nut, adjustment valve step, adjustment valve cap, brass nozzle, adapter body, high-pressure inlet connector, valve seat, valve core plug, valve sleeve, retaining nut, coupler body, and locking sleeve. All of the components are then sent to Malaysia where the pressure washer nozzles, foam cannons and guns are constructed by CNC machining the stainless-steel or brass, depending on the component, precision drilling the parts, and deburring to form the finished products. Once the metal components are made, they are then assembled with the remaining Chinese components to form the complete nozzles, foam cannons and guns. The nozzles, foam cannons and guns are then tested and packaged for retail sale. The five pressure washer tips in item one are placed in a clear blister plastic face, molded over a sturdy cardboard backing card. The foam cannon and tips in item two are placed in a white molded plastic insert before being placed in a sturdy retail box. The packaging for item three is the same as item two but includes additional spaces for the gun and adapter. The pressure washer gun in item four is placed in a clear blister plastic face, molded over a sturdy cardboard backing card. 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. Based upon your description of the manufacturing operations, we note that a significant amount of the components that comprise the nozzles, foam cannons and guns are manufactured in Malaysia. Additionally, these components along with the minor rubber and plastic Chinese components emerge with a new name, character, and use, different from those possessed by the raw metal material. Thus, based on the totality of the circumstances, the country of origin of the 5-piece pressure washer nozzle tip set (SKU T03-NK2), the foam cannon kit (SKU S02-A02K), the foam cannon kit with soft-grip short pressure washer gun (SKU S02-A02K2), and the short pressure washer gun with rigid plastic handle (SKU P01-XQ06) 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 Jason Christie at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division