The country of origin of a red heat bulb

N363554August 12, 2026OT:RR:NC:N4:410
CATEGORY: OriginBella XuZhongyuan Technology (Thailand) Co., Ltd7/554 Moo.6 T., Mapyangporn A.Pluakdeang,RayongRayong 21140ThailandRE: The country of origin of a red heat bulbDear Ms. Xu:In your letter dated
July 23, 2026
, on behalf of your client, Tractor Supply Co., you requested a country oforigin ruling on an R40 Red Heat Bulb (“heat bulb”) for purposes of marking and applying current traderemedies.The manufacturing process is summarized as follows:The heat bulb is assembled in Thailand using components from China and Thailand. Components from Chinainclude the glass envelope and the screw lamp base. Parts made in Thailand include the stem, tungstenfilament, support wires, lead-in wires, exhaust tube, heat deflector, and rigid support rods. The factory inThailand builds these local components and joins them with the Chinese-origin components to finish theproduct.The manufacturing steps in Thailand include:Filament forming and bracket weldingAssembly and sealing of the bulbEvacuation and gas fillingInstallation of the lamp baseFinal packagingThe provided information shows that the Chinese components make up about 66 percent of the totalcomponent cost. The glass envelope alone accounts for roughly 57 percent of the total component cost.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 Ruling
Letter 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).Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unlessexcepted, every article of foreign origin imported into the United States shall be marked in a conspicuousplace as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such amanner as to indicate to the ultimate purchaser in the United States, the English name of the country of originof the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should beable to know by an inspection of the marking on the imported goods the country of which the goods is theproduct. 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 shouldinfluence his will.” See United States v. Friedlander & 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 thecountry of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBPRegulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, orgrowth of any article of foreign origin entering the United States. Further work or material added to an articlein another country must effect a substantial transformation in order to render such other country the “countryof origin” within the meaning of the marking laws and regulations.Based on the provided assembly and manufacturing process scenario, we find that although the factory inThailand produces certain components and its assembly involves some complex steps, the majority of theprocesses are simple in nature. The glass envelope and the lamp base are made in China. These componentsaccount for most of the value and are essential to the structure and proper functioning of the final product.Thus, a substantial transformation does not occur in Thailand.Accordingly, we conclude that the country of origin for the heat bulb is China for purposes of marking andapplying 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