The country of origin of electric salt and pepper grinders

N363318
August 6, 2026
OT:RR:NC:N4:410
CATEGORY: Origin Sheila Yang Yienn Lih Enterprises Co., Ltd 25 Hsin Ye Road Tainan Taiwan RE: The country of origin of electric salt and pepper grinders Dear Ms. Yang: In your letter dated August 13, 2026, you requested a country of origin ruling for purposes of country of origin marking and applying current trade remedies. The merchandise under consideration includes an electric salt grinder and an electric pepper grinder (the “salt and pepper grinders” or “grinders”), which are identical in construction. The difference between the two grinders is limited to their use with either salt or pepper. Thus, the manufacturing process for the grinders in Taiwan is identical. The manufacturing process is summarized as follows: The grinders will be assembled in Taiwan using components sourced from China and components produced in Taiwan. The components sourced from China are the stainless steel upper section housing, motor with its gear set, PCB (Printed Circuit Board), battery, thrust washer, spring, base plate, aluminum shaft, and coarseness adjustment knob. The remaining components—the plastic base, spindle support/centering bracket, retaining clip, adjustment rod, base locking insert, welded retaining ring, and stainless steel threaded insert—are made in Taiwan. The factory in Taiwan fabricates these components through plastic injection molding and metal machining. In the final assembly, the imported components will first be assembled into an upper section (referred to as the “SS upper housing") and then combined with the Taiwan-originating components to make the finished product. The provided information indicates that the Chinese-origin components, which mainly form the upper section and the drive mechanism, contribute approximately 80 percent of the total cost. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. This office has reviewed the provided assembly process descriptions. We are of the opinion that because the upper section is the most expensive and substantial assembly, it imparts the essential character of the electric grinders by driving the mechanism that grinds the salt or pepper. The components of the upper section and the drive mechanism are from China and are assembled into an upper section subassembly with a simple assembly process such that the upper section does not become a new article having a new name, character, or use. Further, we find that the manufacturing process performed in Taiwan in totality would be considered simple assembly in nature, and thus a substantial transformation does not occur in Taiwan. We also note that this manufacturing scenario is similar to the one in ruling N362360 (July 8, 2026), which determined that China was the country of origin for the grinders. The primary difference is that in N362360, the upper section was imported from China as a completed subassembly. In this scenario, the upper section is assembled in Taiwan using components from China. Accordingly, the country of origin for the salt and pepper grinders will be China for the purposes of country of origin marking and applying the current trade remedies. 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 Customs and Border Protection Regulations (19 C.F.R. 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, please contact National Import Specialist Michael Chen at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division