OT:RR:NC:N1:113
Jessica Islas-Parker
A.N. Deringer, Inc.
173 West Service Rd.
Champlain, NY 12919
RE: The country of origin of male and female hose menders
Dear Ms. Islas-Parker:
In your letter dated April 7, 2026, you requested a country of origin ruling on male and female hose menders
on behalf of your client, Meridian International Co., Ltd. Descriptions, technical information, and
photographs were submitted with your request.
The items under consideration are a male hose mender and a female hose mender, which are connectors
designed to be attached to non-industrial hoses that are used in residential gardening applications. Both items
are predominately made of zinc. They each have a narrow barbed cylinder on one end, an octagonal bolt
head in the middle, and a threaded cylindrical shaft on the other end. The male hose mender is threaded on
the exterior of the shaft, and the female hose mender is threaded on the interior. In their finished state, they
are also fitted with stainless steel clamps along their barbed ends.
In your submission, you provided a description of the production process. The raw materials to produce both
mender types are from Cambodia, where they are forged and punched into their approximate shape and size.
The menders are then shipped to China where they undergo machining processes and are fitted with
accessories. This results in the final product, which is then packed in cartons and shipped to the United
States.
When determining the country of origin, 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).
The manufacturing processes used to produce the menders are similar to those of the fittings used for a
corrugated connector described in New York Ruling N355143, dated October 22, 2025. Like the fittings, the
menders are not fully functional in the country they are forged in, they are formed to the approximate shape
and size of the finished product. After forging, the menders are shipped to China to undergo machining
processes and preparing their surfaces for use. The machining and surface treatment for the menders in China
do not constitute a substantial transformation because the menders retain the name, character, and use they
acquired from the country in which they were forged. With the menders undergoing a similar process to that
of the fittings in N355143, no new article emerges from the manufacturing processes in China. Accordingly,
the country of origin of the male hose mender and the female hose mender is Cambodia.
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 Matthew Gay at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division