The country of origin of an electrical receptacle and light switch

N316438 January 8, 2021 OT:RR:NC:N2:220 CATEGORY: Origin Kelly Raia Blue Tiger International 19 Benjamin Ave. East Moriches, NY 11940 RE: The country of origin of an electrical receptacle and light switch Dear Ms. Raia: In your letter dated December 11 2020, you requested a country of origin ruling on behalf of your client, Wiremold Company (Legrand). There are two items submitted for our review. The first item under consideration is identified as the 3232TRB Outlet (receptacle), which is described as a 15 A 125 V electrical receptacle having two three-prong sockets. The receptacle is intended to be installed within a building’s electrical circuit to provide power to various devices. The second item under consideration is identified as the 660B Light Switch, (switch) which is described as a 15 A 125 V single pole electrical switch that consists of a thermoplastic toggle and frame. The switch is intended to control the flow of electrical current by changing the operating lever position. In your request, you state that the receptacle, which is comprised of a plastic molded housing containing electrical contacts, a metal strap assembly, molded plastic shutters, springs, terminals, and screws, is manufactured in Vietnam from raw materials and components produced in Vietnam, China, and the United States. In Vietnam, the electrical contacts are stamped from Chinese origin brass. Also in Vietnam, the plastic housing, cover, and shutter are plastic injection molded from Chinese origin PVC. The subsequent assembly process of the receptacle that occurs in Vietnam includes inserting the terminal strips and the metal strap into the rear half of the molded plastic body, attaching two mounting screws to the metal strap, and ultrasonically welding the rear half to the front. The receptacle is then inspected, tested for overall functionality, and packaged for exportation. You state that the switch, which is comprised of a plastic molded housing containing electrical contacts, terminals, springs, a metal strap, and a molded plastic operating lever, is also manufactured in Vietnam from components produced in Vietnam, China, and the United States. In Vietnam, the electrical contacts are stamped from Chinese origin brass. Also in Vietnam, the plastic housing and operating lever are plastic injection molded from Chinese origin PVC. The subsequent assembly process that occurs in Vietnam includes inserting the electrical contacts, springs, and terminals into the molded plastic body, then the cover and operating lever are inserted, and finally the strap joins the body together by riveting. The switch is inspected, tested for overall functionality, and packaged for exportation. The “country of origin” is defined in 19 CFR 134.1(b) 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”. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character or use, different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 69 C.C.P.A. 151 (1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). Regarding the country of origin of the receptacle and the switch, in our view, the stamping of the electrical contacts in Vietnam results in a substantial transformation of the Chinese brass. Furthermore, it is the opinion of this office that the electrical contacts, to include the strap, provides the essence of the finished receptacle and switch because they are the articles within the assemblies that make the electrical connections. As such, we find that the components that make up the receptacle and switch are transformed in Vietnam into new and different articles of commerce with a name, character, and use. Thus, the 3232TRB Outlet and the 660B Light Switch are considered products of Vietnam at the time of importation into the United States. 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 Karl Moosbrugger at karl.moosbrugger@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division