The country of origin of laminated veneer lumber door stiles

N315890 December 11, 2020 MAR-2-44:OT:RR:NC:1:130 CATEGORY: Country of Origin Mr. Clinton Yu, Esq. Barnes & Thornburg, LLP 1717 Pennsylvania Ave NW #500 Washington, DC 20006 RE: The country of origin of laminated veneer lumber door stiles Dear Mr. Yu: In your letter, dated November 14, 2020, you requested a binding country of origin ruling on behalf of your client, Composite Technology International, Inc. (“CTI”). Manufacturing information was provided for our review. Your request concerns the country of origin of laminated veneer lumber (LVL) stiles used in the manufacture of steel doors. These stiles are the vertical members forming the framework of a hollow-core door. LVL is an engineered wood panel constructed of many veneers of wood, glued one on top of another, with the grains of the veneers running parallel. You state that the instant goods measure approximately 42.88mm wide by 725.49mm-2437.66mm in length, and 20.64mm-29.97mm in thickness. At time of importation, the stiles will also be worked with lock or hinge “strikes”, i.e., bores or routing that are designed to accept lock or hinge hardware, respectively. In your letter, you describe a scenario wherein manufacturing of the stiles will take place in both China and Cambodia. Large LVL panels measuring approximately 580mm wide by 4,300mm will be manufactured in China and shipped to Cambodia for further manufacturing. In Cambodia, the large LVL panels will be sawn into strips that are approximately 43mm in width. These “blanks” will be planed, trimmed, and finger-jointed for length. They will be profiled throughout their length by processing through a molder. The shaped LVL will then be coated with gesso and dado-cut on the ends for assembly. The blanks are then routed or bored to accept hinge and lock hardware. Finally, the stiles are primed, finished, and inspected. Section 134.1(b) of the Customs Regulations (19 CFR 134.1(b)) provides that the "[c]ountry 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 Part 134, Customs Regulations (19 CFR Part 134). Substantial transformation requires that "[t]here must be a transformation; a new and different article must emerge, ‘having distinctive name, character, or use.’" Anheuser-Busch Brewing Association v. United States, 207 U.S. 556, 28 S. Ct 204 (1908). We must therefore determine if or where a substantial transformation of materials occurs in order to determine country of origin. While many operations occur in the manufacturing of the stiles, it is the addition of the lock and hinge “strikes” that alters the LVL into a stile that is dedicated solely for use as a part of a door. After routing or boring the piece to allow it to accept hinge or lock hardware, the stiles are no longer merely veneered panels; they are door parts that are not suitable for any other use. The resulting goods are no longer LVL or veneered panels; they are new and different articles with a distinctive name, character or use – door stiles. Because the LVL is worked with lock and hinge “strikes” in Cambodia, the country of origin of the door stiles is Cambodia. 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. You should also be aware 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 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 Laurel Duvall at laurel.duvall@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division