The country of origin of a ceramic coated chef’s knife from Indonesia.

N306332 October 9, 2019 CLA-2-82:OT:RR:NC:N4:415 CATEGORY: Country of Origin Ms. Kathy Trotta Conair Corporation 150 Milford Road East Windsor, NJ 08520 RE: The country of origin of a ceramic coated chef’s knife from Indonesia. Dear Ms. Trotta: In your letter dated September 3, 2019, you requested a country of origin ruling. The product under consideration is an eight-inch ceramic coated chef’s knife. The knife is made from stainless steel and then coated with a ceramic finish. The knife’s edge is not coated and remains exposed steel. The handle is constructed from plastic. In your submission, you state the blade/tang is formed and the edge is applied in Indonesia. The blade will then be shipped to China where it will be finished and the handle will be applied. It will also be packaged and shipped to the United States from China. With regard to the appropriate country of origin marking of the chef’s knife, section 304, Tariff Act of 1930, as amended (19 USC 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article. Certain types of articles must be marked in a specified manner as required by 19 CFR 134.43. Knives are specifically identified in this regulatory provision as articles that must be marked legibly and conspicuously by die stamping, cast-in-the-mold lettering, etching, or engraving. However, Customs has previously ruled that such articles may be excepted from individual marking if the marking of their containers will reasonably indicate the origin of the articles pursuant to 19 CFR 134.32(d). Pursuant to Part 134, Customs Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 USC 1304. Section 134.1(b), Customs Regulations (19 CFR 134.1(b)), defines “country of origin” as: “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.” A substantial transformation occurs when an article emerges from a process with a new name, character or use different from that possessed by the article prior to processing. A substantial transformation will not result from a minor manufacturing or combining process that leaves the identity of the article intact. See United States v. Gibson-Thomsen Co., 27 C.C.P.A. 267 (1940); and National Juice Products Association v. United States, 628 F. Supp. 978 (Ct. Int’l Trade 1986). From the provided documentation, it is in the opinion of this office that this article obtains its essential character of the finished knife once the blade has been formed and the edge applied. The steps that follow in China would be considered simple assembly that does not change the knife into a new and different article of commerce. As such, the country of origin for this eight-inch ceramic coated chef’s knife would be Indonesia. This ruling is being issued under the provisions of Part 177 of the Customs 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 kristopher.burton@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division