The country of origin of a metal headband from Cambodia.

N353597
October 9, 2025
OT:RR:NC:N4:415
CATEGORY: Origin Jimmy Tsang Moimui Creations Limited Flat J, 18/F, King Palace Plaza, 55 King Yip Street, Kwun Tong, KLN Kwun Tong, Hong Kong, 852 China RE: The country of origin of a metal headband from Cambodia. Dear Mr. Tsang: In your letter dated September 11, 2025, you requested a country of origin ruling. An image was provided in lieu of a sample. The product under consideration is described in your request as a metal tiara. This headband features plastic combs to secure the tiara to the wearer’s head. Your submission indicates that the metal tiara body, acrylic gems, and ribbon are all sourced from China. The headband, plastic combs, and the screw used in assembly are sourced from Cambodia. Further, you state this product undergoes the following processing in Cambodia: 1. The rhinestones are selected and glued to the designated spots. 2. Colored epoxy is applied into the grooves/patterns of the tiara body. 3. The tiara body piece is screwed onto the headband. 4. The combs are glued to the ends of the headband and then wrapped with ribbon to further secure them. 5. The completed product undergoes a quality check and is altered as needed. 6. The tiara headband is packaged and labelled. 7. They are then packaged into boxes for shipping to the United States. 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 is of the opinion that Cambodian sourced metal headband and plastic combs hold the basic nature of the finished tiara headband, and they do not become a new article having a new name, character, or use after the Chinese components are attached in Cambodia. Therefore, the country of origin for this metal tiara headband will be Cambodia. 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 CBP 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, contact National Import Specialist Kristopher Burton at [email protected].
Sincerely,
(for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division