The country of origin of an iron decoration from Cambodia.

N363765
August 4, 2026
OT:RR:NC:N4:425
CATEGORY: Origin Ms. Gina Zhou Carryfar Gift (Cambodia) Company Limited Prey Popel Village, Peuk Commune, Angk Snuol District, Kandal Province, 080107 Cambodia RE: The country of origin of an iron decoration from Cambodia. Dear Ms. Zhou: In your letter dated July 27, 2026, you requested a country of origin ruling for an iron decoration from Cambodia. The merchandise in question is identified as SKU# 6058315, Christmas Cow, an iron decoration depicting a cow wearing a Santa hat, scarf and sweater. The approximate dimensions of this item are 18” (L) x 8.75” (W) x 19.75” (H). 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). According to the information provided in your request, the metal decorations are made from iron sheet metal from Cambodia, pressed into Chinese molds in Cambodia. The pieces are welded together in Cambodia, the decorations are then polished, powder coated and painted in Cambodia prior to packing and shipping to the United States from Cambodia. You have provided photographs of all necessary machinery and the entire production process in sequence. This office agrees that the country of origin of SKU 6058315, Christmas Cow is Cambodia. 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 Sandra Carlson at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division