The country of origin of a digital coin counting bank

N352655
August 27, 2025
OT:RR:NC:N4:410
CATEGORY: Country of Origin Dan Chen Best for Vietnam Manufacturing Co., Ltd. Chau Son Industrial Park, Chau Son Ward Phuly City, Ha Nam Province Phuly 315600 Vietnam RE: The country of origin of a digital coin counting bank Dear Mr. Chen: In your letter dated August 20, 2025, you requested a country of origin determination on a digital coin counting bank for purposes of current trade remedies. The digital coin bank automatically tracks or counts the coin deposits and displays the total on an analog display. It features a large capacity coin jar with removable lid for easy to the deposited coins. The Bill of Materials (BOM) lists the components of the digital coin counting bank as follows: Chinese-origin components Springs, macro and micro axles, positive and negative electrodes, PCB board (printed circuit board), certain discrete electronic components for the PBC, press key, electric wires, LED screen, zebra bar and press buttons. The Vietnamese-origination components Plastic rings, index dial, battery housing, screen and battery covers, bracket, pulleys, jar in addition to the instruction manual and packaging materials. The PCBAs are fabricated through the surface mount technology (SMT) operation in Vietnam. SMT is a process whereby various of components are directly mounted onto a PCB using solder paste and automated placement. The plastic components are made through plastic injection molding.

In the final stage, the Vietnamese-originating components are combined with the imported components to make the finished products involving operations of welding, clipping, etc., and the final testing and inspection. 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). Regarding the country of origin of the digital coin counting bank, we are of the view that a significant number of the parts or components are made in Vietnam, the manufacturing process, including the SMT process and plastic injection molding along with other assembly operations, is 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. Therefore, the country of origin of the digital coin counting bank is 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