N362214

N362214 July 7, 2026 OT:RR:NC:N1:102 CATEGORY: Origin Gerald Francese TradeLaw PC PO Box 1114 110 Tom Harvey Road Westerly, RI 02891 RE: The country of origin of plunger pumps Dear Mr. Francese: In your letter dated June 10, 2026, you requested a country of origin ruling on behalf of your client, Jereh Energy Equipment and Technologies Corporation. The articles at issue are referred to as plunger pumps, model numbers JR600, JR600N, JR600S, JR1000Q, JR1000QS, JR1600Q, JR2500QL, JR2500Q, JR2500HD, JR2800Q, JR2800HD, JR3500D, JR3500HD, JR4000HD, JR5000QPE, JR5000QPW, JR7000QPE and JR7000E. The pumps, which feature 3 or 5 cylinders, continuously operate at 5600 horsepower and provide a maximum output of up to 7000 horsepower. The reciprocating linear motion of the plunger causes the expansion and contraction of the sealed cavity in the fluid end, realizing the suction and discharge of liquid. The gearbox transmits power to the crankshaft and other components. The pump is used primarily in the oil exploration and development industry for oilfield exploitation, oil and gas field fracturing, and high-pressure fluid transportation. With respect to origin, two scenarios detail the final assembly of the plunger pump in the United Arab Emirates (UAE). In both scenarios, a fluid end subassembly and seven additional subassemblies are produced in the UAE and joined together. In the first scenario, these seven subassemblies are manufactured using raw materials from China. In the second scenario, the seven subassemblies are produced using raw materials from China, South Korea, and Turkey. For the crankcase subassembly, oil holes undergo grinding and polishing processes to remove iron filings, burrs and flash. Bearings are disassembled and cleaned. Afterwards, the oil circuits are ground, polished, cleaned, and the plugs are tightened. A bearing retainer plate is then affixed to the lower end face of a bearing component, which is heated. Once cooled, the assembly is fixed with the bearing retainer plate. Afterwards, cooled cylindrical pins are placed into the crankshaft. The upper and lower parts of a connecting rod assembly are mounted onto the crankshaft using positioning pins, and an adapter plate is installed on the lower connecting rod and secured in place using screws. A data cable and protective spring of a temperature sensor are compressed and press-fit into the connecting rod seat assembly. Subsequently, outer rings of a bearing are cooled, installed onto the numbered crankcase bearing seats in sequence and fastened to outer rings with bolts. Bearing stoppers are installed using lock nuts and the outer ring of a bearing is interfaced onto the designated bearing seat and secured in place. Afterwards, a valve box is bolted to the crankcase, and the bores are machined to final dimensions. Using a press-fitting process, the end bearing shells are assembled onto the cast crosshead body. For the crosshead housing subassembly, lifting lugs are assembled onto a crosshead housing, which is followed by the installation of cylindrical pins into the pin holes of a crosshead sliding sleeve. Afterwards, end bearing shells are press-fit onto the cast crosshead body, and a connecting rod bushing is installed into the pin hole of the connecting rod shank. Next, a crosshead pin is installed into the crosshead component and connecting rod small-end bushing. Lastly, a data wire hole of the pony rod is aligned, and a data wire is fastened in place. As these steps are completed, the crosshead housing assembly is joined to the crankcase assembly. For the spacer subassembly, an O-ring and lip seal are installed into the outer sealing grooves of a pony rod oil seal cover. An oil seal baffle is then fastened onto the pony rod oil seal cover. The resulting assembly is bolted onto a spacer, and a crankshaft rotary joint is inserted into the central hole on the non-drive side of the crankshaft. In the next step, greased cylindrical pins are installed into the locating pin holes. And a crosshead box assembly is mounted onto the crankcase and bolted in place. The crosshead assembly is aligned to the studs at the upper part of the connecting rod, and a spacer is installed onto the crosshead housing assembly. The resulting assembly is screwed to the crosshead housing assembly, and the pony rod oil seal is assembled onto the spacer assembly and bolted in place. A fluid end subassembly is mounted onto the spacer assembly, and the resulting process is inspected, ensuring firm mating between fluid end, crankcase, crosshead housing and spacer assembly. Symmetrical multi-stage tightening is completed. For the gearbox subassembly, O-rings are installed into the grooves sequentially and an oil return baffle is secured in place. A gearbox assembly is secured to the crankcase assembly using lock washers and hex nuts, and a bearing retainer plate is secured onto the bearing housing on the drive side of the crankcase. Lastly, a level dial indicator is mounted. The completed gearbox assembly is then installed into the assembly that includes the previously joined subassemblies. For the suction subassembly, an end plug is screwed into the tail groove, which is followed by the installation of a pipe fitting. The pipe fitting is interfaced with the manifold and afterwards an O-ring is installed. The manifold is then positioned onto the fluid end assembly using washers and screwed in place. Afterwards, the subassemblies joined in the previous steps are appropriately fastened. Primer is applied to the mating surfaces, and the process continues by mounting and fastening a complete pump onto a base assembly. Once complete, a fixing block is embedded into a limit block, which is afterwards installed onto an end plate. Large washers, plain washers, and hex nuts are then installed in sequence and tightened. During the next step, a rubber scraper assembly is installed onto a scraper bracket and screwed in place. Connectors and barbed fittings are installed into the corresponding ports of the manual ball valve, which is subsequently installed into the oil pan welding assembly. The process continues by screwing a handle onto the oil pan assembly. Each completed pump is subjected to testing and is packaged for importation. It is mentioned that lubricant, grease and anti-seize compound are applied throughout the assembly process. 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). Additionally, 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

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). Additionally, 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 oth