OT:RR:NC:N1:102
Richard O'Neill
Neville Peterson LLP
701 Fifth Avenue, Suite 4200-2159
Seattle, WA 98104
RE: The country of origin of a faucet
Dear Mr. O'Neill:
In your letter dated August 25, 2025, on behalf of your client, Globe Union North America Group, you
requested a country of origin ruling to apply current trade remedies and for marking purposes.
The product at issue is a two-handle faucet, model number F8FA0069. The faucet, which can be installed in a
lavatory, is comprised of two handles, a body, an aerator, cover plates and cartridge valves.
With respect to origin, the final assembly of the faucet occurs in China and begins with cartridge valve s from
Taiwan undergoing various tests and inspections. Afterwards, two cartridge valves are inserted into the valve
chambers of a faucet body and secured in place using a retaining nut. In the next step, the two handles are
attached to a valve stem and fastened in place with set screws. Subsequently, the cover plates and an aerator
are installed onto the spout section of the faucet body. Once complete, the faucet undergoes final testing.
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. Friedlander & 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.
The final assembly processes described above are rather simple and do not constitute a substantial
transformation. The processes performed in China do not change the shape, character, or predetermined use
of the cartridge valves, which are recognized in Headquarters Ruling Letter H321630, dated June 27, 2022,
as the essential component of faucets. Therefore, as the country of origin of the cartridge valve s is Taiwan,
the country of origin of the faucet is Taiwan.
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)
Denise Faingar
Acting Director
National Commodity Specialist Division