RE: The country of origin of a pressure washer adapter set and turbo nozzle

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 N364862 September 16, 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 a pressure washer adapter set and turbo nozzle Dear Ms. Li: In your letter dated September 4, 2026, you requested a country of origin ruling on a pressure washer adapter set and turbo nozzle. Descriptive literature was provided for our review. The first item under consideration is described as a pressure washer adapter set (SKU A02-B03K), which is a multi-piece hardware kit designed to provide seamless, leak-free connections between a variety of high-pressure cleaning components. The set consists of a stainless-steel straight swivel adapter, and a brass quick connect, garden hose connect, and garden hose male plug adapter. The universal kit is designed to withstand extreme operating pressures up to 5,000 PSI, making it compatible with both commercial gas and residential electric power washers. The set is primarily utilized to convert threaded connections into fast-snap joints and reduce setup and breakdown times by allowing users to quickly swap out spray guns, extension wands, surface cleaners, and high-pressure hoses. The second item under consideration is described as a pressure washer turbo nozzle (SKU T01-N01-B). This accessory is designed for attachment to high-pressure spray lances to facilitate the cleaning of unpainted hard surfaces. The device utilizes an internal ceramic rotor that, when subjected to water pressure, rotates to convert a concentrated, zero-degree stream into an oscillating, 360-degree cone-shaped spray pattern. It combines the force of a pencil jet with the coverage area of a fan nozzle to remove grime, moss, and rust. The nozzle is composed of brass and stainless-steel components, encased in a rubberized protective sleeve, and features a standard 1/4-inch quick-connect inlet plug. The adapters and nozzles are made from components sourced from China and Malaysia. The Chinese components include the stainless-steel (for the quick connect and quick plug), compression springs, retaining rings, O-rings, locking balls, rubber grip, and plastic filter elements. The Malaysian component is the brass bar stock used for the brass nut, brass nozzle body, brass sealing fitting, brass stem, coupler body, and
locking sleeve. All of the components are then sent to Malaysia where the adapters and nozzles are constructed by CNC machining the stainless-steel or brass depending on the component, precision drilling the parts, deburring and inspecting to form the finished components. Once the metal components are made, they are then assembled with the remaining Chinese components to form the complete adapters and nozzles. The adapters and nozzles are then tested and packaged for retail sale. Item one is then placed into white retail box for shipment to the United States. Item two is placed in a brown retail box. 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 adapters and nozzles are manufactured (CNC machined) 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 pressure washer adapter set (SKU A02-B03K) and pressure washer turbo nozzle (SKU T01-N01-B) 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