RE: The country of origin of polyvinyl chloride (PVC) pressure washer hoses

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 N364861 September 17, 2026 OT:RR:NC:|N5:137 CATEGORY: Origin Sarah Li Autowin Group Limited Unit 08, 15/F Witty Commercial Building Kowloon Hong Kong 999077 RE: The country of origin of polyvinyl chloride (PVC) pressure washer hoses Dear Ms. Li: In your letter dated September 4, 2026, you requested a country of origin ruling on PVC pressure washer hoses. The products under consideration are SKU C06K-25, a 25 ft. hose; SKU W01-P05-D, a 50 ft. hose; SKU C06K-100, a 100 ft. hose; and SKU C06K-200, a 200 ft. hose. The hoses are 3200 PSI Kink Resistant, pressure washer replacement/extension hoses. They consist of a PVC hose, two steel fittings, two steel crimp sleeves and two coupling nuts (polyamide-6 (PA6) and aluminum alloy). The hoses will be used with a pressure washer, connecting the pressure washer to the spray gun to deliver high-pressure water for surface cleaning tasks. The four hoses undergo the same manufacturing process. Manufacture of the components: Chinese origin steel round bar stock, PVC pellets, steel crimp sleeves and (PA6+aluminum alloy) coupling nuts are shipped from China to Malaysia. The following processes take place in Malaysia: The Chinese origin steel bar stock is loaded into a CNC machine. It undergoes CNC turning, hole drilling and deburring into the steel fittings. The Chinese origin white PVC pellets are extruded into the inner tube. Cord is wrapped around the outer surface of the inner tube to provide support and reinforcement. Chinese origin PVC pellets are extruded over the reinforcing cord to form the outer layer of the hose. Assembly of the hose: The plastic coupling nut (PA6+aluminum alloy) is installed on the hose. Steel fitting is inserted into the hose bore.
The hose is inserted into the crimping machine to crimp the fittings into place. The finished hose undergoes quality control testing and packing for shipment. 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). The manufacturing and assembly processes taking place in Malaysia constitute a substantial transformation. Therefore, the country of origin of the pressure washer hoses 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 Christina Allen at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division