The country of origin of gas griddles from Thailand

N361088May 20, 2026OT:RR:NC:N4:410
CATEGORY: OriginSteven CottoBaker McKenzie815 Connecticut AvenueWashington, DC 20006RE: The country of origin of gas griddles from ThailandDear Mr. Cotto:In your letter dated
April 28, 2026
, made on behalf of your client Weber-Stephen Products LLC, yourequested a country of origin ruling for the purposes of China Section 301 trade remedies application.The merchandise under consideration is referred to as Slate 17” and 22” griddles, which is two models of gasgriddles. The griddles differ primarily in respect to the number of burners and cooking space - the Slate 17”features one burner and 272 inches of cooking area and the Slate 22” features two burners and 352 inches ofcooking area.In your request, you illustrate that the Slate 17” and 22” griddles would be assembled in Thailand withcomponents sourced from China and produced in Thailand. The components sourced from China are burnertubes, valves, and legs. The factories in Thailand will fabricate the balance of the components orsub-assemblies including the lid, cookbox, and griddle, and combine these components or sub-assemblieswith the China-origin components to make the finished products which includes the operations of metalforming, bending, punching, stamping, and or deep-drawing.Specifically, the manufacturing process in Thailand encompasses the following five major steps:Assemble the accessory kitThe Thai factory assembles the accessory kit by packaging the drip pan, tank holder, hardware bag, and lidhandle into the accessory kit package.Assemble the valveThe Thai factory then assembles the valve sub-assembly by installing the valve onto a gas line, testing thevalve under low and high pressure, and recording the results.
Deep draw, paint, and assemble the lidThe Thai factory deep draws the lid, paints the lid, and attaches the lid top hinge to the lid, and attaches thelogo badge and warning label to the lid.Deep draw and assemble the cookboxThe Thai factory deep draws and enamels the cookbox from sheet metal and stamps the grease chute andgriddle bracket, and then installs the catch pan rail, cookbox feet, leveling foot sub-assembly, side rail (wherethe valve sub-assembly is hosted), and other attachments before ignition testing the cookbox.Final assembly for shipmentLastly, the Thai factory packages the lid sub-assembly, cookbox sub-assembly, and accessory kit intocardboard packaging for shipment.When determining the country of origin for purposes of applying current trade remedies under Section 301and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters RulingLetter H301619, dated November 6, 2018. The test for determining whether a substantial transformation willoccur is whether an article emerges from a process with a new name, character, or use different from thatpossessed 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 descriptions and is of the opinion that factories inThailand produce a significant number of components, including key components, i.e., the main lids,cookbox, and griddle from the material of sheet steel; the non-Thai origin components underwent enough of achange to afterwards emerge with a new name, character, and use that is different from what they possessedprior to processing, thus completing a substantial transformation. Therefore, from the details submitted, weagree that the country of origin for the Slate 17” and 22” griddles would be Thailand for the purposes ofapplying the current trade remedies, China Section 301 remedies do not apply.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Michael Chen at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division