N365288

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365288 October 8, 2026 OT:RR:NC:N1:102 CATEGORY: Classification; Origin TARIFF NO.: 8414.20.0000 Icey Huang Autowin Group Limited Flat/RM 08, 15/F Witty Commercial Building 1A-1L Tung Choi Street Mongkok, Kowloon, Hong Kong China RE: The classification and country of origin of a siphon tube set Dear Ms. Huang: In your letter dated September 22, 2026, you requested a ruling regarding the classification and country of origin of a siphon tube set. Item number AU8561 is identified as a siphon tube set, also referred to as a multi-use liquid transfer pump kit. The set consists of a manually actuated pump that is retail packaged with two siphon hoses, an inflation hose, an extension hose, hose sleeves, a hose connector, a plastic inflator head, an air chuck assembly, and a stainless-steel needle. The pump and the accessories packaged with the pump allow air or liquids to be transferred. In your letter, you suggest the pump imparts the essential character of the set and therefore the siphon tube set is classified within subheading 8413.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Pumps for liquids, whether or not fitted with a measuring device; liquid elevators; part thereof: Hand pumps, other than those of subheading 8413.11 or 8413.19. While we agree the pump imparts the essential character of the set, the design of the pump and the accessories allow it to function as either an air or a liquid pump not just as a liquid pump. Because of the dual-functionality, CBP has previously classified a similar multi-use pump set in accordance with GRI 3(c) within heading 8414, which provides for air pumps. See New York Ruling Letter G89404, dated April 12, 2001. The applicable subheading for the siphon tube set will be 8414.20.0000, HTSUS, which provides for Air or vacuum pumps, air or other gas compressors and fans; ventilating or recycling hoods incorporating a fan, whether or not fitted with filters; gas-tight biological safety cabinets, whether or not fitted with filters; parts thereof: Hand or foot operated air pumps. The general rate of duty is 3.7 percent ad valorem. With respect to origin, the pump is assembled in Malaysia using components from China and Malaysia (specifically a barrel and two caps). To assemble the pump, a top elbow cap is manually assembled into a piston rod assembly, the component that features the manual actuator and a moving piston. Subsequently, a retaining ring, a piston base cap, and a bottom elbow cap are manually placed on the barrel in sequence. During these steps, the piston rod assembly with the top elbow is inserted into the barrel. Once complete, the pump is tested and packaged with the components described above. 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). Here, components from China and Malaysia (a barrel and two caps) are assembled together in Malaysia to produce a pump. When considering the assembly processes required to produce the pump, the operations are not particularly complex, as the components are manually inserted or installed in place. These processes do not result in a substantial transformation. Because the assembly processes described in the submission do not result in a substantial transformation and given that the majority of the components, including the piston rod assembly, are from China, the country of origin of the pump is China. Therefore, the country of origin of the siphon tube set is also 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 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 Sandra Martinez at sandra.martinez@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division

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). Here, components from China and Malaysia (a barrel and two caps) are assembled together in Malaysia to produce a pump. When considering the assembly processes required to produce the pump, the operations are not particularly complex, as the components are manually inserted or installed in place. These processes do not result in a substantial transformation. Because the assembly processes described in the submission do not result in a substantial transformation and given that the majority of the components, including the piston rod assembly, are from China, the country of origin of the pump is China. Therefore, the country of origin of the siphon tube set is also 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 U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we not