The country of origin of iron wire hangers from Mongolia

N317385 February 22, 2021 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Country of Origin Mr. Keith Chan QHD Inc. 20955 Pathfinder Road #360 Diamond Bar, CA 91765 RE: The country of origin of iron wire hangers from Mongolia Dear Mr. Chan: In your letter dated February 4, 2021, you requested a country of origin ruling. Photographs of the iron wire in rolls and videos of the production of the subject hangers were submitted with your ruling request. The articles under consideration are identified as iron wire garment hangers for sale to the laundry industry. Each hanger features a non-swivel hook at the top and measures approximately 1.8 millimeters (mm) in diameter. In your letter you indicated that the iron wire is packed in bulk rolls in China and shipped to the factory in Mongolia. You stated that “After the iron wire is imported into Mongolia and delivered to the factory, we will put/set the iron wire in a roll on the hanger making machine. The machine will automatically pull the wire and bend the wire into the shape of a hanger. The factory will spray coat the iron wire hanger in order to make sure the hanger will not damage your hands as well as not damage the garment when hanging it on the hanger.” The finished hangers will be shipped from Mongolia to the United States and will be sold in their condition as imported. As stated in Headquarters Ruling Letter 735009 dated July 30, 1993, “The country of origin is the country where the article last underwent a substantial transformation, that is, processing which results in a change in the article's name, character, or use.” Customs and Border Protection maintains, based on United States v. Gibson-Thomsen Co., 27 C.C.P.A. 267 (C.A.D. 98) (1940), that “A substantial transformation occurs when an article emerges from a manufacturing process with a name, character, and use that differs from the original material subjected to the processing.” Regarding the iron wire hangers at issue, the cutting, shaping and coating performed in Mongolia constitute a substantial transformation because the resulting product is a new article in which the name changes from wire to hanger. The manufacturing processes performed in Mongolia result in an article which has a new name, character and use. Therefore, it is our opinion that the country of origin of the iron wire hangers is Mongolia. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Ann Taub at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division