The country of origin of nickel key fob logos

N361357June 3, 2026OT:RR:NC:N5:121
CATEGORY: OriginDavid ForgueBarnes, Richardson & Colburn, LLP303 East Wacker Drive, Suite 305Chicago, IL 60601RE: The country of origin of nickel key fob logosDear Mr. Forgue:In your letter dated
May 7, 2026
, you requested a country of origin ruling on nickel key fob logos on behalfof LaFrance Corporation. Photographs and descriptions of the merchandise were included in your inquiry.The merchandise under consideration is described as key fob logos. These logos are made of nickel andpainted.You describe a manufacturing process in which impressions of the key fob logo are created on a nickelbacking sheet in either China or Japan. Each sheet contains in excess of 300 logo impressions. The sheets arethen shipped to Vietnam where they undergo processing that includes backfilling each impression withepoxy; multiple applications of precision spray painting, cleaning, coating, and curing; cutting eachimpression out of the strips and then placing fewer than 20 logos onto an adhesive strip. Quality controls arecompleted throughout the process, ending with a detailed final inspection. A protective film is applied to eachsheet, and the goods are packaged for shipping.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 holds the opinion that the nickel backing sheets have a predetermined end use, have the basicnature of the finished logos, and that they are not substantially transformed to become a new article having anew name, character, or use after being further processed in Vietnam. Accordingly, the country of origin forthese key fob logos will be either China or Japan. If the nickel backing sheets are manufactured in China,Section 301 duties will apply. The country of origin for marking purposes will be either China or Japan.
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 Jennifer Jameson at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division