OT:RR:NC:N1:102
Tim Anderson
Runfine International Co. Ltd
8N132 Peppertree Lane
Elgin, IL 60124
RE: The country of origin of faucets
Dear Mr. Anderson:
In your letter dated June 13, 2025, you requested a country of origin ruling on behalf of your client, The
Home Depot. Descriptive information was provided for our review.
Stock Keeping Units 1009029257, 1009029258, and 1009029259 are each referred to as the Dual Sensor
Touchless Pull-Down Kitchen Faucet in Brushed Nickel with 4-function Turbo Spray and Fast Mount. The
faucets, which are unassembled sets, consist of a faucet body with a cartridge valve and a solenoid valve, a
battery box, and a sprayer head packaged together ready for retail sale.
The applicable subheading for the Dual Sensor Touchless Pull-Down Kitchen Faucets will be 8481.80.9050,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for Taps, cocks, valves and
similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and
thermostatically controlled valves; parts thereof: Other appliances: Other: Other: Other. The general rate of
duty will be 2 percent ad valorem.
With respect to origin, the assembly of the faucet sets occurs in Thailand and consists of valves, and other
components from China.
To assemble the faucet spout, an oiled O-ring seal is installed into the corresponding connection of the
cartridge valve, which is subsequently installed into the body of a faucet. Then a solenoid valve core
sourced from China is pressed into a seat sourced from China. Afterwards, a lubricated O-ring is installed
into a seal. The seal and O-ring are then installed into a corresponding connector, which is subsequently
installed into the body of the faucet. The core of the solenoid valve is then screwed onto the valve seat.
Next, a spring is installed onto the solenoid valve and afterwards inserted and screwed into the body of a
faucet. Using adhesive, a spout sourced from China is connected to the body of the faucet and screwed in
place. The power cord of the induction module is then connected to the solenoid valve power supply. Once
connected, the power supply is positioned between the gap of the faucet body and the valve, and the induction
module is installed into the induction window. Next, adhesive is applied onto the inlet and outlet water hoses,
and the inlet hose is appropriately installed, and the outlet water hose is screwed into the valve core seat.
Afterwards, a fixed pipe connector is installed into the hose, and adhesive is installed into threads of the inner
wall of the faucet body. Subsequently, the fixed panel is installed into the faucet body and the pipe connecter is
screwed into the faucet body. Lastly, the power cord of the induction module is installed within the cold-water
inlet pipe.
The battery box is also assembled in Thailand, which is completed by screwing a cover to a battery box from
China. Afterwards, batteries are placed in a bag and then taped to the box.
Also, assembled in Thailand are a base plate, a pipe sleeve bushing, and an outlet pipe with a pull-out hose.
The base plate is installed into the fixed pipe connector and snapped in place. The pipe sleeve bushing,
which features a ribbed end facing, is installed into a pipe sleeve and pressed in place. The pull-out bushing
is pressed into the outlet pipe and the pullout hose, which is sourced from China, is manually installed
through the outlet pipe and fixed pipe connector.
Upon completion, a faucet and a sprayer from China undergo air and water leak tests. Afterwards, the
required labeling is added and the spray head is wrapped in paper and packaged. Subsequently, a Chinese
sourced handle is placed on the valve core rod and screwed in place. The faucet and the battery box are then
packaged with the spray head.
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).
With regard to faucets, CBP views processes such as inserting and pressing components to each other as
simple assembly, and has relied on the origin of the valve, as valves are the essential component of faucets.
See Headquarters Ruling Letter H321630, dated June 27, 2022. In this instance, the cartridge and solenoid
valves are of Chinese origin. Therefore, as the country of origin of the valves is China, the country of origin
of the three faucet sets is China.
Products originating from China, unless specifically excluded, are subject to the duties of Section 301 Trade
Remedies. In our present scenario, articles of Chinese origin are packaged together ready for retail sale.
Considering such, we refer to the guidance pertaining to sets packaged for retail sale, which is provided on the
CBP website under “CBP Section 301 Trade Remedies Frequently Asked Questions.” The answer to “How are
the Section 301 duties assessed in respect to sets packaged for retail sale, which contain components covered
by the Section 301 remedy,” reads, in pertinent part, as follows:
When importing goods put up in sets for retail sale (in accordance with General Rule of Interpretation 3) that
contain articles subject to the Section 301 remedy, if the product that imparts the essential character to the set
(i.e., the HTSUS provision under which the entire set is classified) is covered by the Section 301 Trade
Remedy, then the entire set will be subject to the additional duties. For the three faucet sets, the valves,
which are of Chinese origin, are the essential component of the systems. As such, the faucets are subject to the
additional duties applicable to products of China under Section 301 of the Trade Act of 1974, as amended,
upon importation into the United States.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China
and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under
headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent
ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading,
i.e., 9903.01.24, in addition to subheading 8481.80.9050, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99
provisions covering exceptions to the reciprocal tariffs. At this time products from all countries will be subject to
an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading
applicable to your product classification, i.e., 9903.01.25, in addition to subheading 8481.80.9050, HTSUS,
listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8481.80.9050, HTSUS, unless specifically excluded, are subject to an additional 25 percent
ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e.,
9903.88.03, in addition to subheading 8481.80.9050, HTSUS, listed above.
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,
(for)
James Forkan
Acting Director
National Commodity Specialist Division