RE: The country of origin of pressure washer nozzles and a sewer jetter kit

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 N364863 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 pressure washer nozzles and a sewer jetter kit Dear Ms. Li: In your letter dated September 4, 2026, you requested a country of origin ruling on pressure washer nozzles and a sewer jetter kit. Descriptive literature was provided for our review. The first item under consideration is described as a 3-piece sewer jetter nozzle set (SKU T01-N02K). The item is packaged together as a set for retail sale and is designed exclusively for mechanical attachment to high-pressure hydro-jetting equipment or pressure washer hoses to clean, clear, and flush commercial and residential drainpipes. The nozzles are made of corrosion-resistant stainless-steel and contain three distinct spray nozzles designed to direct high-pressure fluid streams. The first is a rotating nozzle featuring an internal spinning mechanism driven by water flow to provide 360-degree scouring action against grease and roots. The second is a button nose nozzle with rear-facing thrust orifices designed to propel the hose forward while flushing loose debris. The third is a pointed jetter nozzle (also referred to as a penetrating or chisel nozzle) configured with a sharp profile and a forward-facing jet to punch through tough blockages and obstructions. The second item under consideration is described as a sewer jetter kit (SKU W02-P02K). The retail-packaged assortment is designed to convert a standard mechanical gas or electric pressure washer into a high-pressure pipe and drain cleaning system. The kit contains a high-pressure thermoplastic hose measuring 1/4-inch in internal diameter, reinforced with dual-layer high-tenacity terylene textile braiding and jacketed in weather and abrasion-resistant polyvinyl chloride (PVC). The hose is terminated at both ends with 1/4-inch Male National Pipe Thread (M-NPT) brass or stainless-steel fittings and possesses a rated maximum working pressure of 5,800 PSI and a burst pressure of 11,000 PSI. Imported alongside and packaged with the hose are several interchangeable hydro-jetter nozzles, including a stainless-steel button-nose nozzle and a brass rotating nozzle. The assortment further incorporates an M22
female-to-1/4-inch NPT female coupler, a 1/4-inch quick-disconnect plug for attachment to a pressure washer spray gun, a roll of polytetrafluoroethylene (PTFE) thread seal tape, two specialized open-ended spanners for fitting installation, and a set of cleaning pins for clearing nozzle orifice obstructions. The components are put up together in a single package for retail sale and function in an interdependent manner to project, disperse, and spray high-velocity water under pressure for the maintenance and cleaning of conduits. The nozzles, hose and adapters are made from components sourced from China and Malaysia. The Chinese components include the stainless-steel (for the nozzle washer, nozzle body, button nose nozzle, pointed nozzle, and fittings), screws, washers, O-rings, PVC plastic pellets for the hose, crimp sleeve, crimp sleeve, springs, retaining ring, and locking balls. The Malaysian components include the brass bar stock used for the nozzle rotating sleeve, female thread bushing, connector, coupler body, and locking sleeve. The plastic pellets are also imported from Malaysia to make the anti-slip sleeve. All of the components are then sent to Malaysia where the metal components are constructed by CNC machining the stainless-steel or brass depending on the component, precision drilling the parts, deburring and inspecting. Once the metal components are made, they are then assembled with the remaining Chinese components to form the complete nozzles and fittings. The hose is made by melting the white PVC plastic pellets and extruding the inner tube. Next, the reinforcing cord is wound around the outer surface of the inner tube to provide support and reinforcement. Then, the black PVC pellets are then extruded over the reinforcing cord to form the outer layer of the hose. The metal pieces are then added to the end of the hose using a crimping machine. All of the nozzles from item one are then tested and packaged in a white retail box. All of the items from item two are then tested and packaged 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 nozzles, adapters and hose are manufactured (CNC machined and extruded) 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 and plastic pellets. Thus, based on the totality of the circumstances, the country of origin of the 3-piece sewer jetter nozzle set (SKU T01-N02K) and sewer jetter kit (SKU W02-P02K) 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