The country of origin of an agitator assembly

N352815
September 2, 2025
OT:RR:NC:N1:102
CATEGORY: Origin Jennifer Liu Vietnam Leili Motor Company Limited No. CN07-06 AND CN07-07, Land Lot No. CN07 Van Trung Industrial Zone, Van Trung Ward Viet Yen Town, Bac Giang Province, 35000 Vietnam RE: The country of origin of an agitator assembly Dear Ms. Liu: In your letter dated August 25, 2025, you requested a country of origin ruling on an agitator assembly. Descriptive information was provided with your submission. The product at issue is an agitator assembly, part number 294D2947G001. The assembly consists of an auger bell crusher connected to a shaft using a washer. Once the product is installed into a double-door household refrigerator and the user selects the crush mode from the refrigerator’s panel, the shaft transfers power to the auger bell crusher, which stirs ice cubes to prevent clumping. The final assembly of the product begins by inserting a shaft from Vietnam into a washer from China. Afterwards, the shaft and washer are joined to an auger bell crusher from China using a hydraulic riveting machine. Once complete, the agitator assembly undergoes inspections. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional 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). Here, the final assembly processes are rather simple and do not constitute a substantial transformation. The processes performed in Vietnam do not change the shape, character, or predetermined use of the inputs. Instead, we look to the origin of the auger bell crusher, as it accounts for the largest amount of the final

product’s value and is the component that completes the actual stirring process, which is the function of the agitator assembly. Therefore, as the origin of the auger bell crusher is China, the origin of the agitator assembly is China. 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 Sandra Martinez at [email protected].
Sincerely,
(for) Denise Faingar Acting Director National Commodity Specialist Division