The country of origin of chrome-plated automotive parts.

N310306 March 18, 2020 CLA-2-39:OT:RR:NC:N4:415 CATEGORY: Country of Origin Mr. M. Jason Cunningham Sonnenberg & Cunningham, PA 780 Fifth Avenue South Naples, FL 34102 RE: The country of origin of chrome-plated automotive parts. Dear Mr. Cunningham: In your letter dated March 02, 2020, you requested a country of origin ruling on behalf of your client, Jing Mei Automotive Limited. There are two products under consideration. The first item is a chrome-plated, plastic, automotive door handle, part number 4927-1000.201, which is for the inside, left-hand (i.e. driver) door handle for a Honda Accord. The driver pulls upon this door handle to open the driver’s door from the inside of the vehicle. Per your submission, it is specifically designed for use in only the Honda Accord. It does not fit nor function in any other vehicle. The second item is a chrome-plated, plastic, mirror shell, part number 776038AC, P552, which is the side view mirror shell for the left (i.e. driver) side of a Ford F-150 pick-up truck. After importation, it will be mounted to the exterior of the driver side door. A side view mirror and associated componentry will be mounted inside of the subject article after importation. It provides protection to the mirror and other internal components and is aerodynamically designed. In your request, you indicated that two countries will be involved in the production of these two products. Country “A” was indicated as being either Hong Kong or India, and Country “B” was notated as being China. It is noted that the Original Equipment Manufacturer (“OEM”) owns the tools used to mold the subject articles and must approve the production location and can change that location. In Country “A,” for the subject door handles, PC-ABS (polycarbonate-acrylonitrile butadiene styrene) resin is dried, then injection molded using the OEM’s tool to make the final form of the door handle. In Country “A,” ABS resin is dried then injection molded to make the final form of the subject mirror shell. At this point, the door handle and mirror shell have the final dimensions, shape, and characteristics of the Honda Accord’s inside left-hand door handle or the Ford F150’s driver side mirror shell. The molded door handles and mirror shells will subsequently be sent to Country “B.” In Country “B,” each of the subject articles will be plated, packaged in bulk, and then exported to the United States. Plating involves a series of chemical baths and electrolytic application so that very thin layers of metal can be attached to the plastic molds in a manner that will perform exceptionally well under the demanding conditions of automotive use. 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: “[t]he 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 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 provided documentation and is of the opinion that these automotive parts undergo what would be deemed a simple manufacturing process, not a substantial transformation, by being chrome-plated and would not emerge with a new name, character, and use that is different from what they possessed prior to this processing. Thus, the country of origin for the automotive door handles and the mirror shells would be Hong Kong or India (Country “A”). 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 Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division