Country of origin determination of string light sets from the Philippines

N303559 April 19, 2019 MAR-2 OT: RR: NC: N4:410 CATEGORY: Country of Origin Mr. James K. Kearney Womble Bond Dickinson (US) LLP 8065 Leesburg Pike, Fourth Floor Tysons Corner, VA 22182-2738 RE: Country of origin determination of string light sets from the Philippines Dear Mr. Kearney: This is in response to your letter dated March 14, 2019, on behalf of your client Everstar Merchandise Co., Ltd. /Tomson Merchandise Co., Ltd., requesting a country of origin determination for string light sets featuring miniature incandescent bulbs. According to your letter, each item is comprised of the following components: a plug, a cord connector, fuses, electric wires, lead contacts, light bulbs, a color box, lamp holders/lamp husks and a UL label. You have stated that all the components are purchased from China (made in China) except for the UL label which is from the United States, and the electric wires and packing materials (carton boxes) are from the Philippines. You illustrated assembly manufacturing steps in the Philippines are as follows: Plug assembly with common wire – assemble the metal and plastic components to make the plug and connect the plug to common wire. End-connector assembly with common wire – Assemble the plastic and metal parts to make the end-connector and connect it to the common wire. Common wire cutting and terminal mounting – Cut the wire spool into wire in specific length using the wire cutting machine and mount the metal terminals to the cut wires. Bulb and lamp holder assembling – Insert the bulbs into the lamp holders using the lamp assembly machine to make the lamps. Light string connecting – Assemble the lamps with the lamp husks, terminals and wires in the light assembly machine to form the light string. Light String assembling and twisting – Connect the light string to the common wire, plug and end connector to make the finished light string. Testing, labeling, packing and inspection. Section 134.1(b), Customs Regulations (19 C.F.R. § 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”. Based on the information submitted, we find that the processing performed in the Philippines with respect to the string light sets does constitute a substantial transformation of all the imported materials into "products of" the Philippines. The manufacturing process in the Philippines transforms the Chinese and American originating components/materials to produce the finished string light sets. It creates a new and different article of commerce with a distinct character and use that is not inherent in the components imported into the Philippines. Therefore, the "product of" requirement has been satisfied. For tariff purposes, it is of the opinion of this office that the country of origin for the string light sets featuring miniature incandescent bulbs will be the Philippines. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 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, contact National Import Specialist Michael Chen at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division