The country of origin of a brass garment hook

N305630 August 29, 2019 CLA-2-83:OT:RR:NC:N1:121 CATEGORY: Origin Clifford O. Chi Hampton Products International Corporation 50 Icon Foothill Ranch, CA 92610 RE: The country of origin of a brass garment hook Dear Mr. Chi: In your letter dated August 1, 2019 you requested a country of origin ruling. The merchandise under consideration is identified as Item #01-3012-418, a brass Garment Hook, Double. The double hook is 1-1/8 inches tall and made of solid brass. According to your request, your proposed manufacturing plan includes producing the hook via a die-cast operation in Taiwan. The cast hook will then be shipped to China for processing that includes polishing, removing die-lines and sharp edges, cleaning, coating the hook with a protective layer and drying. The completed garment hook will then be packaged in China with fasteners of Chinese origin. You state in your request that the garment hook is classified in subheading 8302.50.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Base metal mountings, fittings and similar articles…: Hat-racks, hat pegs, brackets and similar fixtures, and parts thereof. The rate of duty will be free. With regard to your request for the appropriate country of origin of the garment hook, 19 C.F.R. § 134.1(b) provides in pertinent part as follows: Country of origin means 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 this part; As stated in HQ 735009 dated July 30, 1993, “The country of origin is the country where the article last underwent a “substantial transformation”, that is, processing which results in a change in the article's name, character, or use”. In addition, the court has held that “A substantial transformation occurs when an article emerges from a manufacturing process with a name, character, and use that differs from the original material subjected to the processing.” However, if the manufacturing or combining process is merely a minor one that leaves the identity of the article intact, a substantial transformation has not occurred. In order to determine whether a substantial transformation occurs when components of various origins 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. Assembly operations that are minimal will generally not result in a substantial transformation. Based on the information you provided, it is this office’s opinion that the casting of the hook would provide the essence of the garment hook. The hook is not substantially changed by either the addition of the Chinese components or the processing or packaging operations performed in China. The Taiwanese cast hook would provide the essential operational element for the garment hook to function. In view of these facts, the country of origin of the Garment Hook, Double, would be Taiwan. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Jennifer Jameson at jennifer.d.jameson@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division