OT:RR:NC:N1:102
Karia Herrera
RL Jones CHB
1610 Landmark Road
San Diego, CA 92154
RE: The country of origin of a pressure reducing valve
Dear Ms. Herrera:
In your letter dated July 13, 2026, you requested a country of origin ruling on behalf of your client, Acorn
Engineering Company Inc.
Item number YRV03P0-6 is referred to as a pressure-reducing valve. The automatic valve adjusts flow and
pressure based on its settings. The valve is designed to reduce the incoming water pressure, minimizing the
potential for leaks and downstream water consumption.
With respect to origin, the final assembly occurs in Taiwan using components from Taiwan and other
countries.
The final assembly begins by inserting a disc, a disc holder, and a washer into the body seat followed by the
insertion of a top and bottom stem. Next, a diaphragm from the United States and a diaphragm cup are oiled
and installed inside the body seat followed by the insertion of a screen to complete the cartridge assembly.
Afterwards, a strainer bonnet from China, along with a plug is manually screwed onto the valve body from
China. The finished valve is then tested and packaged ready for shipment.
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).
When determining the country of origin of valves, U.S. Customs and Border Protection (CBP) has relied on
the origin of the valve body, the essential component of a valve, as the process of assembling a valve is rather
simple. Components are typically assembled into the valve body using processes such as inserting and
screwing components to each other. Such processes are not regarded as being complex. See New York
rulings N339513 (dated May 6, 2024), N338713 (dated April 3, 2024), N325765 (dated May 26, 2022) and
N322652 (dated December 2, 2021). The same origin rationale is applicable here, as the assembly processes
of the subject valve primarily consist of inserting and placing components to each other.
With regard to the origin of the valve body, it is not until the machining and finishing processes, which occur
in China, that the casting is recognizable as a valve body. It is in China that the features of the valve body are
formed, substantially transforming the casting into a new and different article of commerce with a name,
character, and use distinct from the casting exported from China. As such, the county of origin for the
pressure reducing valve is China.
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 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 Sandra Martinez at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division