CBP Ruling N360156 — The country of origin of salt and pepper mills.

Tariff classification

HTS codes: 1201, 2018, 1982, 1993, 2026, 1992

Headings: 1201, 2018, 1982, 1993, 2026, 1992

Product description

Images were provided in lieu of samples. The products under consideration are salt and pepper mills. The salt mills consist of plastic components sourced from Taiwan, and the metal parts and ceramic grinder are Chinese in origin. The pepper mills also include plastic components obtained from Taiwan, and the metal parts, including the carbon steel grinder, are produced in China. The components of both the salt and pepper mills will be assembled in Taiwan to create the finished items. 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 holds the opinion that the ceramic and metal grinders have a predetermined end use, have the basic nature of the finished mills, and that they are not substantially transformed to become new articles having a new name, character, or use after the simple assembly performed in Taiwan. Accordingly, the country of origin for these salt and pepper mills will be China. The ho

CBP rationale

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 holds the opinion that the ceramic and metal grinders have a predetermined end use, have the basic nature of the finished mills, and that they are not substantially transformed to become new articles having a new name, character, or use after the simple assembly performed in Taiwan. Accordingly, the country of origin for these salt and pepper mills will be 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.

Full text

N360156
April 17, 2026
OT:RR:NC:N4:415
CATEGORY: Origin Cathy Huang Yienn Lih Enterprises Co., Ltd. 25, Hsin Ye Road, An Ping Industrial Zone Tainan, 708 Taiwan RE: The country of origin of salt and pepper mills. Dear Ms. Huang: In your letter dated March 30, 2026, you requested a country of origin ruling. Images were provided in lieu of samples. The products under consideration are salt and pepper mills. The salt mills consist of plastic components sourced from Taiwan, and the metal parts and ceramic grinder are Chinese in origin. The pepper mills also include plastic components obtained from Taiwan, and the metal parts, including the carbon steel grinder, are produced in China. The components of both the salt and pepper mills will be assembled in Taiwan to create the finished items. 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 holds the opinion that the ceramic and metal grinders have a predetermined end use, have the basic nature of the finished mills, and that they are not substantially transformed to become new articles having a new name, character, or use after the simple assembly performed in Taiwan. Accordingly, the country of origin for these salt and pepper mills will be 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 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) James P. Forkan Director National Commodity Specialist Division

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