The country of origin for toaster ovens from Vietnam

N351728
August 20, 2025
OT:RR:NC:N4:410
CATEGORY: Origin Xinjun Ni Midea Consumer Electric (Vietnam) Co., Ltd. NA2 Street, Thoi Hoa Industrial Park, Thoi Hai Ward Ben Cat Town, Binh Duong Province Vietnam RE: The country of origin for toaster ovens from Vietnam Dear Mr. Ni: In your letter dated July 22, 2025, you requested a country of origin determination ruling for the toaster ovens for the purposes of applying current trade remedies. The merchandise under consideration is identified as Toaster Oven II, which covers four different models of toaster ovens: TL-AC264CZA (SS), VCO25RIB, AC25CEW-BS and AC25CEW-SS. You state that differences between the four models are limited to minor variations in oven door design, control panel layout, and exterior finish. These four models of the Toaster Oven II are consistent in terms of use, craftsmanship, and structural assembly and will be considered to as the same toaster ovens for the purposes of this ruling request. You present the following manufacturing process scenario, in which the toaster ovens are produced in Vietnam through a manufacturing and assembly process comprising three main stages. The bill of materials (BOM) indicates that Vietnam accounts for the majority or a significant portion of the production costs of the toaster ovens. Manufacturing process details in Vietnam are outlined as follows: In the first stage, key components are manufactured in Vietnam from various imported and Vietnamese-originating raw materials. The key components such as the left side panel, right side panel, top plate, rear panel, enclosure or outer cover, crumbs tray, and baking tray are produced using Vietnamese-origin hot-dip galvanized steel plate, stainless steel plate, and aluminum steel plate via steel machining operations. In the second stage, the control panel subassembly (comprising the front panel, display panel, power board, button base, control panel, among other parts), door subassembly (comprising oven upper and lower glass inserts, glass door window, handle, among other parts.), and cavity subassembly (comprising left and right side panels, rollers, back plate, top plate, fan assembly, among other parts) are manufactured. The assembly process in this stage goes through numerous processing steps.

The third stage includes the final assembly and testing. Upon completion of the manufacturing of the components and assemblies in Stages 1 and 2, the toaster ovens are ready for final assembly. The final assembly involves placing Vietnamese-produced metal components and assemblies with remaining components (of non-Vietnamese-origin) to fabricate the finished products, testing and packaging. When determining the country of origin for purposes of applying current trade remedies under Section 301, 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). This office reviewed the provided assembly process flow charts and other materials in the submission, and is of the opinion that the Chinese components undergo processing in Vietnam that is sufficiently complex and meaningful as to result in a substantial transformation, such that these components lose their individual identities and become an integral part of a new article, possessing a new name, character, and use. In addition, essential parts are manufactured in Vietnam. Accordingly, from the details submitted, we agree that the country of origin for the toaster ovens would be Vietnam. 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