OT:RR:NC:N5:137
Jessica Islas-Parker
A. N. Deringer
173 West Service Rd.
Champlain, NY 12919
RE: The country of origin of plastic connectors
Dear Ms. Islas-Parker:
In your letter dated April 16, 2026, you requested a country of origin ruling on plastic connectors on behalf of
your client, Meridian International Co., Ltd.
The product under consideration is described as a 4pc Connector Set. The product consists of a hose
connector, a faucet connector and two hose adapters. The components are made up of polypropylene (PP),
acrylonitrile butadiene styrene (ABS) and polyoxymethylene (POM) plastics. They will be packaged together
in a polybag with a header card.
Female quick connector water stop:
The subcomponents, female connector, female quick connector shell and water stop plug, are
injection molded in Cambodia using Cambodian raw materials. The subcomponents,
thermoplastic rubber (TPR) overmolded shell, washer, o-ring and spring, are manufactured in
China. The Cambodian origin subcomponents are shipped to China where they are combined
with the Chinese origin subcomponents to form the female quick connector water stop.
Male quick connector:
The subcomponents, male connector and male quick connector shell, are injection molded in
Cambodia using Cambodian raw materials. The subcomponents, TPR overmolded shell. and
spring, are manufactured in China. The Cambodian origin subcomponents are shipped to
China where they are combined with the Chinese origin subcomponents to form the male
quick connector.
Female adapter:
The subcomponent, female adapter, is injection molded in Cambodia using Cambodian raw
materials. The subcomponents, washer and o-ring, are manufactured in China. The
Cambodian origin female adapter is shipped to China where it is combined with the Chinese
origin washer and o-ring to finish the female adapter.
Male adapter:
The subcomponent, male adapter is injection molded in Cambodia using Cambodian raw
materials. The subcomponent, o-ring, is manufactured in China. The Cambodian origin male
adapter is shipped to China where it is combined with the Chinese origin o-ring to finish the
male adapter.
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).
The Explanatory Notes (ENs) to the Harmonized Tariff Schedule of the United States (HTSUS) constitute the
official interpretation of the tariff at the international level. EN X to General Rule of Interpretation (GRI)
3(b) provides: “for the purposes of this Rule, the term "goods put up in sets for retail sale" shall be taken to
mean goods which: (a) consist of at least two different articles which are, prima facie, classifiable in different
headings; (b) consist of products or articles put together to meet a particular need or carry out a specific
activity; and (c) are put up in a manner suitable for sale directly to users without repacking (e.g., in boxes or
cases or on boards).”
Each of the items in the “4pc Connector Set” are classified in the same heading. Therefore, the “4pc
Connector Set” is not a GRI 3(b) set. Accordingly, the country of origin of each of these items will be
determined separately.
The essential character of the female quick connector water stop is imparted by the water stop plug which is
injection molded in Cambodia. Accordingly, the country of origin for the female quick connector water stop
will be Cambodia.
The essential character, of the male quick connector, female adapter and male adapter, is imparted by the
Cambodian origin subcomponents. Accordingly, the country of origin of the male quick connector, female
adapter and male adapter will be 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 Christina Allen at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division