OT:RR:NC:N1:118
Fangyi Tian
Autowin Group Limited
Flat/Rm. 08, 15/F
Witty Commercial Building
1A-1L Tung Choi Street
Mongkok, Kowloon, Hong Kong
China
RE: The country of origin of a Valve Core Tool
Dear Ms. Tian:
In your letter dated June 3, 2026, you requested a country of origin determination for marking purposes under
Section 304 of the Tariff Act of 1930, as amended (19 U.S.C 1304).
Item SP021 is identified as a Valve Core Tool. It is designed to remove and install Schrader valve cores in
vehicle tires, bicycles, and other inflatable equipment. The tool is comprised of a plastic handle, steel shaft,
integrated plastic-on-steel shaft assembly, and a steel compression spring.
You have stated that all core manufacturing operations for the Valve Core Tool occur in Malaysia from raw
materials sourced from Malaysia and China. The manufacturing processes that occur in Malaysia include
plastic injection molding, CNC turning, and nickel electroplating. The tool is assembled in Malaysia with a
Chinese-origin compression spring and then undergoes testing before it is packaged for retail sale.
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. Friedlaender & 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.
A substantial transformation occurs when, as a result of manufacturing process, a new and different article
emerges, having a distinct name, character or use, which is different from that originally possessed by the
article or material before being subjected to the manufacturing process. See United States v.
Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940).
Regarding the country of origin of the Valve Core Tool, it is our view that raw steel and plastic are
substantially transformed in Malaysia into a finished tool. As demonstrated in your production flow charts,
all core manufacturing and finishing operations occur in Malaysia. Therefore, the country of origin of the
Valve Core Tool, item SP021, is Malaysia.
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 Anthony Grossi at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division