OT:RR:NC:N1:102
Lisa Murrin
Expeditors Tradewin LLC
795 Jubilee Drive
Peabody, MA 01960
RE: The country of origin of a water pump
Dear Ms. Murrin:
In your letter dated March 25, 2025, on behalf of Gates Corporation, you requested a country of origin ruling
of a water pump for the purpose of Section 301 Trade Remedies. A description of the assembly processes
was provided in the submission.
The water pump at issue consists of an aluminum or iron housing that encases an impeller, bearings, seals,
and a pulley. The size of the water pump corresponds to its motor vehicle application.
In regard to origin, you describe two scenarios: in scenario one, the final assembly of the water pump occurs
in Mexico and in scenario two, the final assembly of the water pump occurs in China. The final assembly for
both scenarios consists of the following processes.
A Chinese manufactured Water Pump Roughcast (housing) is placed on a fixture and a Chinese weep cover
(end cap) is pressed into one of housing’s openings. In the following process, a Chinese manufactured
integral shaft bearing and a seal from China are pressed into the opening of the housing. Next, an impeller
manufactured in the United States is pressed onto the bearing shaft. Afterwards, a Chinese manufactured
pulley is installed onto the bearing shaft and the housing. Once the components are appropriately placed, the
components are bolted in their location. It is noted that during the final assembly processes, an O-ring and a
sealing gasket from China are installed in the appropriate locations.
When determining the country of origin for purposes of applying current trade remedies under Section 301,
the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (HQ) 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).
Here, the final assembly processes completed for both scenarios are rather simple and do not constitute a
substantial transformation.?Pressing components into the housing or onto a shaft and securing them in place
using bolts is not complex in nature.?The processes performed in Mexico or China do not change the shape,
character, or predetermined use of the inputs. Therefore, like the pump end in HQ H313089, dated February
16, 2021, we look to the origin of the impeller to determine the origin, as it is the essential component of the
water pump. The impeller provides the force necessary to displace fluid. As the impeller is of United States
origin in both scenarios, the country of origin of the finished water pump for both scenarios is the United
States.
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 Sandra Martinez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division