The country of origin of three oven lights

N351073
August 4, 2025
OT:RR:NC:N4:410
CATEGORY: Origin Long Chen Thai Jiuzhou Electron Co., Ltd. 88/152 Moo 15 Bangsaotong Sub-District Bangsaotong 10540 Thailand RE: The country of origin of three oven lights Dear Mr. Chen: In your letter dated July 8, 2025, you requested a country of origin determination on three oven lights for purposes of current trade remedies. The merchandise under consideration is referred to as Item 1 Wall Oven Lamp (191D7209G007, 191D7209G008), Item 2 Wall Oven Lamp (191D7477G004), and Item 3 Apex Lamp (301D1481G001). The Bill of Materials (BOM) and the component pictures indicate that the Oven Wall Lamps in Item 1 and Item 2 appear to be highly similar in construction, except for the shape of the light head (housing or case). Each oven lamp has a glass lens, a metal housing containing a ceramic lamp socket, a light bulb, and electrical wires with plug or connector at either end (referred to as “harness” in Item 1 and Item 2). Additionally, Item 2 has a metal clip. The Apex Lamp (Item 3) has a glass lens, metal case (housing), metal pin, light bulb, and socket with two pins for connection to a power supply. The procedures for the making of components are illustrated as follows: Glass Lens Melting the sand and molding the liquid to shape glass lens. Metal Case, Metal Clip and Metal Pin Cutting the stainless steel sheet and making the metal case by progressive stamping mold. Ceramic Lamp Socket and Plug Pouring a ceramic powder slurry/sand into the mold and then firing it in a kiln to fuse the particles together. After firing, the ceramic component is then assembled with the metal terminals.

Bulb Forming a coil of metal to make the wire, melting the sand to make a glass tube, and mounting the metal filament inside a glass bulb. Finally, attaching the connectors to the bulb for electrical connection. Harness Clamping the terminals to the electrical wires to make the harness. The terminals and the wires are made in China via operations of metal drawing, plastic extrusion, etc. Connector and Retainer Melting the plastic pellet and making the plastic parts via plastic injection molding operations. The factory in Thailand will assemble the Thai-origin components and components imported from China (of Chinese-origin) to produce the finished lights. Specifically, you present two different manufacturing process scenarios as follows: Scenario 1 The assembly process for the lamps in Thailand is summarized as follows: Item 1 - The metal case, and bulb are made in Thailand, the glass lens, ceramic, connector, and retainer are imported from China. The harness is made by clamping the terminals to the wires in Thailand from the imported electric wires and terminals. Item 2 - The metal case, bulb, and metal clip are made in Thailand, the glass lens, ceramic, connector, and retainer are imported from China. The harness is made by clamping the terminals to the wires in Thailand from the imported electric wires and terminals. Item 3 - The metal case, metal pin, and bulb are made in Thailand; the glass lens and ceramic socket are imported from China. Scenario 2 The assembly process for the three oven lights in Scenario 2 notes that all components are imported from China except for the bulbs, which will be produced in Thailand. The final assembly procedures in Thailand involve manually combining the Thai-origin components and the imported components via clamping and riveting machines (for items 1 and 2) and laser-soldering (for Item 3 only). When determining the country of origin for purposes of applying current trade remedies under Section 301 and other 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). This office reviewed the assembly process for the two product scenarios. We note that, in the first scenario, a number of parts and components are produced in Thailand, the manufacturing process including the making of light bulbs and the metal parts along with other assembly operations (e.g., laser soldering), is considered

sufficiently “complex and meaningful”, in which the non-Thai origin components are substantially transformed in Thailand when they are used in the production of the oven lights. We find that the country of origin for the oven lights will be Thailand in the first scenario. In the second scenario, only the light bulbs will be produced in Thailand. The simple assembly of the imported components would not constitute a substantial transformation due to it not being sufficiently complex and meaningful to result in the non-originating components to lose their individual identities and become an integral part of a new article, possessing a new name, character, and use. Therefore, we find that the country of origin for the oven lights will be China in in the second scenario. 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 Michael Chen at [email protected].
Sincerely,
(for) James Forkan Acting Director National Commodity Specialist Division