The country of origin of an electric fireplace insert from Cambodia.

N346613
April 8, 2025
OT:RR:NC:N4:415
CATEGORY: Origin Stacia Keegan RIM Logistics 1303 Jack Court Barlett, IL 60103 RE: The country of origin of an electric fireplace insert from Cambodia. Dear Ms. Keegan: In your letter dated March 10, 2025, you requested a country of origin ruling on behalf of your client, GHP. The product under consideration is described as the “RTA fireplace insert.” It is an electric fireplace insert with a light emitting diode (LED) feature that provides the appearance of a burning fire. This fireplace insert is assembled in Cambodia mainly from parts sourced from Cambodia. The remaining parts are of Chinese origin. We note that several of the key components such as the heating element, the printed circuit boards (PCBs), and much of the frame/housing are sourced in Cambodia. The following manufacturing steps are performed in Cambodia: 1. The bottom plate assembly with the synchronous motor bracket component is made. 2. The shading board is added to the bottom plate assembly. 3. The artificial logs are attached to this assembly. 4. The LED board is assembled. 5. Reflective strips are affixed to this assembly. 6. The base plate components are assembled with additional trim parts to create the frame structure of the finished insert. 7. The wiring is organized and attached to the PCB. 8. The LED board is plugged in and checked for appearance issues. 9. The blower components are assembled and added to the completed frame. 10. The power cord is assembled and the cable clipped. 11. The power board is affixed to the interior. 12. The corresponding terminals are inserted into the power board. 13. Wiring is further organized and tied. 14. All leads are routed and secured as required. 15. The top panel is assembled and added to the frame components, finishing the assembly of the insert.

When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (?HQ?) 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). In order to determine whether a substantial transformation occurs when components are assembled into completed products, all factors such as the components used to create the product and manufacturing processes that these components undergo are considered in order to determine whether a product with a new name, character, and use has been produced. No one factor is decisive, and assembly/manufacturing operations that are minimal will generally not result in a substantial transformation. This office reviewed the assembly process, which are relatively minor and do not amount to a substantial transformation in Cambodia.?Based on the parts breakdown and technical narrative submitted in your request, it is the opinion of this office that the Cambodian parts, including the heating element and the PCBs, impart the essential identity and functionality to the electric fireplace insert. As such, we hold the opinion that the country of origin for this product is Cambodia based upon the origin of these components. 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 CFR 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 Kristopher Burton at [email protected].
Sincerely,
Steven A. Mack Director National Commodity Specialist Division