Country of origin determination of a vanity light fixture

N308656 January 14, 2020 CLA-2 OT:RR:NC:N4:410 CATEGORY: Country of Origin Mr. Kenneth Lu Arcadian Lighting, Inc. 14820 Central Ave. Chino, CA 91710 RE: Country of origin determination of a vanity light fixture Dear Mr. Lu: This is in response to your letter dated December 31, 2019, requesting a country of origin determination for a vanity light fixture, which is a wall mount three-light fixture. The vanity light fixture consists of a back plate, cross bar with arms, lamp holders and clear glass shades. All of the major components are imported from China and subsequently assembled into the finished product in Burma. The assembly process in Burma starts with cutting the insulated wire and copper (for terminals) spools into specific length and stamping the terminals into the wires. The ceramic socket, copper fitting, and cooper bands are stamped with rivets and affixed to the insulated wires with terminals to make the lampholder. The lampholders are fastened to the cross bar/arms. The back plate is fastened to the cross bar, and the fixture is then properly wired to form the lighting fixture. Finally, the clear glass shades are affixed to the lampholders with a decorative metal screw cap to complete the assembly process. The finished products are tested, inspected, and packed with materials produced in Burma. Section 134.1(b), Customs Regulations (19 C.F.R. § 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”. The assembly operations performed in Burma do not substantially transform the Chinese originating components into the products of Burma. The assembly of the individual components does not create a new and different article of commerce with a distinct character and use that is not inherent in the components imported into Burma. The components of the vanity light, e.g., electrical wires, terminals and socket parts, cross bar/arms and glass shades, etc., do not lose their individual identities as a result of the assembly process in Burma. The components of the vanity light have a pre-determined end­use as parts and components of the light when imported into Burma, and do not undergo a change in use due to the assembly process in Burma. Based on the information submitted, the processing performed in Burma does not constitute a substantial transformation. Therefore, the country of origin for the vanity light will be China and the Section 301 measures will apply. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 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 Michael Chen at michael.w.chen@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division