RE: The country of origin of electric stove heaters

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 N365344 October 9, 2026 OT:RR:NC:N 4:410 CATEGORY: Origin Angel Roman Campos Muncy, Geissler, Olds & Lowe PC 125 S. Royal Street Alexandria, VA 22314 RE: The country of origin of electric stove heaters Dear Mr. Campos: In your letter dated September 23, 2026, on behalf of your client, Jiangmen Lingfeng Electric Appliances Manufacturing Co., Ltd., you requested a country of origin ruling on electric stove heaters for purposes of applying current trade remedies. The merchandise under consideration is referred to as Electric Stove Heater Model H3D-B15 (the “Stove Heater”). Model H3D-B15 is an electric stove heater designed to provide heated airflow while presenting the appearance of a traditional stove/fireplace through a decorative illuminated log assembly. The heating function is produced through the coordinated operation of a resistance heating element, electric motor, and wind-turbine/fan assembly. The heating element generates heat, while the motor drives the wind-turbine assembly to move air through the heating system and distribute the heated airflow. The Thailand-manufactured PCBA provides the appliance's electronic control functions, including temperature and heating control, fan interlock, user-interface functions, safety monitoring and protection, flame-effect control, and power management. These functional components are incorporated into a fabricated metal housing together with the front door, decorative illuminated log assembly, wiring, safety components, and related hardware. The Stove Heater is manufactured in Thailand from components and materials originating in Thailand, Vietnam, and China. The resistance heating element is manufactured in Vietnam. In Thailand, however, significant motor manufacturing and assembly occur; the heating element is incorporated into the heating system and integrated with the motor and wind-turbine assembly; the metal housing is fabricated; and the various electrical, structural, heating, and decorative components are assembled into the finished appliance. The completed Stove Heater is also tested and inspected in Thailand. You describe the manufacturing process in Thailand as follows:
A. Motor Manufacturing The motor is not imported into Thailand as a completed foreign-origin motor. In Thailand, lacquered wire and related inputs are used to manufacture the coil assembly through coil winding and wiring, lead-wire preparation and soldering, insulation, and performance testing. The completed coil assembly is then inserted into a China-origin stator. A China-origin rotor with shaft and gear housing are subsequently assembled with the stator/coil assembly, and the motor components are fastened together. The completed motor undergoes electrical and performance testing in Thailand, including hi-pot, noise, current, leakage-current, and low-voltage startup testing. Thus, although the stator and rotor with shaft originate in China, significant motor manufacturing and assembly operations occur in Thailand before the motor is incorporated into the Stove Heater. B. Heating and Wind-Turbine Assembly The resistance heating element itself is manufactured in Vietnam and shipped to Thailand. The completed heating assembly is not manufactured in Vietnam. In Thailand, the imported heating element is installed into the heating box to form the heating assembly. That assembly is then installed into the wind-turbine assembly, and the motor is incorporated into the combined heating and airflow system. The resulting assembly undergoes performance testing and inspection in Thailand. Thus, although the resistance heating element originates in Vietnam, the complete forced-air heating system is created through the integration of the heating element, motor, and wind-turbine assembly in Thailand. C. Metal Housing and Final Assembly The metal housing is fabricated in Thailand from coated sheet through multiple punching, trimming, deburring, hemming, bending, and forming operations. The functional and structural systems are then integrated into the finished Stove Heater in Thailand. The Thai operations include assembly of the housing, switches and circuit board, installation of the heating/motor/wind-turbine system, assembly of the front door and rear board, and final product integration. The finished unit undergoes aging, performance testing, appearance inspection, packaging, and storage in Thailand. The remaining identified China-origin components include the power cord, switch, lead wires, flame-effect lighting assembly, screws, and nuts. 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). In regard to the country of origin of the electric heaters, the motor and the heating element are key components that together generate and propel heat, thereby delivering the essential functionality of the product. The subject merchandise would not function for its intended use without these key elements. The motor is assembled in Thailand using a Thai-origin coil assembly and an imported stator, rotor, and other motor components; the imported heating element is then incorporated into the heating system and combined with the wind-turbine assembly and motor to create the functional forced-air heating system. Further, the
Thai-origin subassemblies (including the PCBs produced through surface-mount technology procedures) represent the most technically complex and functionally significant inputs into the final product. The metal housing is also created in Thailand from coated sheet metal through multiple punching, trimming, deburring, hemming, bending, and forming operations. Based on the totality of facts, it is our view that the manufacturing process in Thailand is complex and meaningful; thus, a substantial transformation has occurred there. Consequently, the country of origin for the electric stove heaters will be Thailand for purposes of applying 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