OT:RR:NC:N4:410
Monique Corona
Professional Plumbing Group Inc.
51 Lacrue Avenue
Glend Mills, PA 19342
RE: The country of origin of a garbage disposal from Thailand
Dear Ms. Corona:
In your letter dated April 13, 2026, you requested a country of origin ruling for the purposes of current trade
remedy application.
The merchandise under consideration is identified as Mini Garbage Disposal, Part Number 85495 (the
“garbage disposal”). You state that the garbage disposal is a compact, high-torque continuous feed food
waste disposer. The garbage disposal is powered by ¾ horsepower with a 1700 RPM Motor. It features
durable, rust-resistant stainless steel grinding components, which grinds food into smaller particles making
for easier passing of food waste through pipes, leading to less clogging. The disposal is installed under
household kitchen sink cabinet.
The garbage disposal is comprised of components from China and Thailand. These components are
assembled in Thailand. The manufacturing processes performed in Thailand are divided into the following
stages:
Quality Inspection: Prior to assembly in Thailand all foreign and Thailand-origin components are visually
inspected. This step ensures components are free from defects that may compromise the product’s integrity.
Motor Assembly: This operation involves assembling the Thailand-origin garbage disposal shell, motor,
access plate and bushing with the China-origin assess screw, electric cord and wire grommet to make the
motor assembly. The processing steps include pressing the garage disposal shell to fit over motor; installing
the access plate and access plate screw to the underside of the garbage disposal motor; and installing the
bushing, wire grommet, and 36’ electrical cord to the underside of the garbage disposal motor.
Drain Assembly: This operation involves the assembling the Thailand-origin stopper, sink flange, backup
flange, mounting ring, lower mounting ring and top with the China-origin rubber gasket, fiber gasket, snap
ring, mounting screws, baffle and gasket to make the drain assembly. The processing steps include installing
the stopper, sink flange, rubber gasket, backup flange, mounting ring, snap ring all and securing these
components in place using mounting screws; inserting the top and gasket onto motor assembly; and affixing
the baffle and lower mounting ring to secure drain assembly to motor assembly.
Side Piping Assembly: This operation involves using the Thailand-origin discharge tube flange, discharge
tube and the China-origin rubber cove, discharge screw and discharge tube washer to make the piping
subassembly.
Quality Control and Packaging: This operation involves conducting the electrical and quality control testing
to ensure the finished product operates properly and meets all regulatory requirements. The system is dried
and cleaned, discharge tube is removed and unit is packaged for retail sale.
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).
This office reviewed the manufacturing process and is of the opinion the non-Thailand origin components
lost their identity and are substantially transformed when they are combined with the Thailand-origin
components and assemblies in Thailand. The manufacturing operation in Thailand creates a new and
different article of commerce with a distinct character and use. In addition, the motor assembly, which is a
critical component of the garbage disposal, is made in Thailand. Accordingly, the country of origin for the
disposer is Thailand for the purposes of applying the current trade remedies.
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 Michael Chen at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division