The country of origin of salt and pepper mills.

Product description

Images were provided in lieu of samples. The products under consideration are a salt and pepper mill both with wooden bodies. The pepper mill features components sourced from China and Taiwan, with the carbon steel inner and outer grinder being produced in China. Similarly, the salt mill consists of components sourced from China and Taiwan, with the ceramic inner and outer grinder also being Chinese in origin. The components of both the salt and pepper mill 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. We note these mills are similar to the ones ruled upon in N360156, dated April 17, 2026, and we maintain the opinion that the carbon steel and ceramic 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 s

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. We note these mills are similar to the ones ruled upon in N360156, dated April 17, 2026, and we maintain the opinion that the carbon steel and ceramic 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.

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