The country of origin of a windchime from Vietnam

N361370June 1, 2026
CATEGORY: OriginGina ZhouTwinkle Tide Smart Home Co. LtdLot No. B3-B4, Tan Hoi 1 Industrial Park, Hoi An HamletTan Hoi Commune, ,Tan Chau District, Tay Ninh ProvinceVietnamRE: The country of origin of a windchime from VietnamDear Ms. Zhou:In your letter dated
May 8, 2026
, you requested a country of origin ruling on a windchime for purposes ofcurrent trade remedies.The product under consideration is a windchime that measures approximately 31.5 inches in height and 8inches in diameter. Each windchime consists of a dome-shaped metal top piece with metal tubes, flowers, aclapper and a bee windcatcher, all suspended beneath. Three metal chains are connected to a hook at the topof the dome for hanging.In your ruling request submission and subsequent email correspondence, you state that the windchimes areassembled in Vietnam using components sourced from both China and Vietnam. The components sourcedfrom China include the top pieces, flowers, clappers, bees, and windcatchers. The components of Vietnameseorigin are the hooks, chains, and tubes. The factory combines these Vietnamese-origin components with theChinese-origin parts to create the finished windchimes.Specifically, the assembly process in Vietnam begins with manufacturing the steel hooks, chains, and tubesthrough metal forming, laser cutting, bending, and shaping. Next, the Chinese-origin components areintegrated with these Vietnamese-produced parts through welding, polishing, powder coating, paint spraying,and hand-painting. Finally, the finished products undergo testing and inspection before being packaged forexport.The Bill of Materials (BOM) demonstrates that the manufacturing operations in Vietnam contributesapproximately 80% of total cost of production and final value of the windchimes.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 asubstantial 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).This office reviewed the provided assembly process descriptions and is of the opinion that the factories inVietnam produce certain components including the hooks and chains and tubes from the material of sheetsteel and wires; the non-Vietnamese origin components undergo enough of a change to afterwards emergewith a new name, character, and use that is different from what they possessed prior to processing, thuscompleting a substantial transformation. Therefore, the country of origin for the windchime at issue isVietnam for the purposes of applying the current trade remedies.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