RE: The classification and country of origin of poured wax candles.

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N363812 August 26, 2026 CLA-2-34:OT:RR:NC:N4:415 CATEGORY: Classification; Origin TARIFF NO.: 3406.00.0000 Thuy Thi Thanh Pham GHGP International Trading Company Limited Lot 58, 4.3-ha Resettlement Area, An Bien Ward Hai Phong, 180000 Vietnam RE: The classification and country of origin of poured wax candles. Dear Ms. Pham: In your letter dated July 28, 2026, you requested a classification and country of origin ruling. Images were provided in lieu of samples. Two candles, RS 16 oz Striped Ceramic Candle (Green), SKU 6109610, and RS16 oz Striped Ceramic Candle (Blue), SKU 6109611, contain citronella oil and will be addressed separately under ruling N364522. There are five scented candles under consideration. They are all made with a blend of palm and paraffin wax, cotton wicks, and will be poured into a decorative glass container. The specific candles subject to this request are listed as follows: 10 oz Spring Icon Glass Candle (Yellow), SKU 6109605, 10 oz Spring Icon Glass Candle (Green), SKU 6109606, 10 oz Spring Icon Glass Candle (Red), SKU 6109603, RS 10OZ Americana Chick Icon Candle, SKU 6110549, and RS 10OZ Americana Star Icon Candle, SKU 6110550. The applicable subheading for these candles will be 3406.00.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[c]andles, tapers and the like.” The general rate of duty is Free. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. Your submission indicates that all processing of the below components is performed in Vietnam, to include the melting and pouring of the wax to form the finished candles. Description: Country of Origin: Vessel, glass (10 oz) China
Wax China Fragrance, fragrance oil varies by SKU United States Wick Vietnam Wick Clip Vietnam Packaging Vietnam 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. This office reviewed the submitted documentation explaining the manufacturing process for these candles, and we hold the opinion that the Chinese origin wax and vessels are substantially transformed to become a new article having a new name, character, or use after being processed in Vietnam. Thus, the country of origin for these candles will be Vietnam. Your products may be subject to prohibition and recall under the laws and regulations administered by the U.S. Consumer Product Safety Commission (CPSC). You are advised to contact the CPSC to determine if your merchandise complies with pertinent safety standards and regulations. Import compliance information may be obtained by contacting the Office of Compliance, Consumer Product Safety Commission, 4330 East West Highway, Bethesda MD 20814-4408, by calling (301) 504-7912 or by e-mail contact through their website at www.cpsc.gov. 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 CBP Regulations (19 CFR 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, contact National Import Specialist Kristopher Burton at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division