OT:RR:NC:N5:116
Mr. Stephen L. Fodor
Customs Services & Solutions, Inc.
6576 Church St.
Douglasville, GA 30134
RE: The country of origin of seamless stainless steel pipe fittings
Dear Mr. Fodor:
In your letter dated January 18, 2026, you requested a country of origin ruling for the purposes of applying
trade remedies on behalf of your client, Metalworks Ningbo Aida, Inc.
The products to be imported are described as push fittings and PEX fittings. According to your submission,
the components that make up the push fittings are manufactured in China and consist of a stainless steel cast
body, an O-ring, a stainless steel sleeve, plastic rings, and a grip ring. The completed components are shipped
to Cambodia where the stainless steel cast body is machined, tumble-polished, cleaned, dried, and tested. The
components are then assembled and the stainless steel sleeve is crimped around both ends of the cast body.
The PEX fittings are imported from China into Cambodia as stainless steel tubes. In Cambodia, the tubes are
cut to length and bent into an elbow shape. They are then machined to create the barbs that hold the PEX
tubing onto the stainless steel fittings. Once the manufacturing is complete the fittings are tumble-polished,
cleaned, dried, and tested.
When determining the country of origin for purposes of applying current trade remedies 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).
You indicate that components from China are sent to Cambodia to create the push fittings. It appears there is
no manufacturing that takes place in Cambodia. All of the components are complete when they are imported
into Cambodia. Based on the information provided, the components are only assembled, cleaned, and tested
in Cambodia. This office finds that the operations performed in Cambodia do not result in a substantial
transformation since a new and different article does not emerge. The components enter Cambodia as an
unassembled fitting and are imported into the United States (U.S.) as complete, assembled fittings. As such,
we find that the country of origin of the push fittings for trade remedy purposes is China.
The documentation indicates that stainless steel tubes from China are sent to Cambodia to create the PEX
fittings. In Cambodia, the tubes are cut and bent to form the shape of the elbow fittings. After the cutting and
bending, the elbow fittings are machined to create the barbs necessary for the fittings to perform their
function. Based on the information provided, the tubes require additional manufacturing in Cambodia in
order to perform their intended function. This office finds that the operations performed in Cambodia result
in a substantial transformation since a new and different article emerges. As such, we find that the country of
origin of the PEX fittings for trade remedy purposes is Cambodia.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification, the merchandise covered by this ruling may also need to be reported with either the Chapter 99
provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to
such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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 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, contact
National Import Specialist Angelia Amerson at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division