The country of origin of vacuum cleaners

N324519 March 23, 2022 MAR-2 OT: RR: NC: N4:410 CATEGORY: Country of Origin Ms. Lauren Wyszomierski White & Case LLP 701 13th Street NW, Suite 600 Washington, DC 20005 RE: The country of origin of vacuum cleaners Dear Ms. Wyszomierski: This is in response to your letter dated February 24, 2022, on behalf of your client Midea America Corporation, requesting a country of origin determination for vacuum cleaners. The merchandise under consideration is vacuum cleaners identified as the NEU700 Series. The NEU700 Series is an upright vacuum cleaner designed for household use. The vacuum’s power is 1400W, and its dust cup capacity is 2.3L. The vacuum cleaners are packaged for sale to individual consumers to be used as an upright vacuum. Each unit is sold in a single package together with its corresponding accessories. The models within the series vary slightly because they are sold into different markets with different color schemes, different accessories, or slightly different features. However, the models all use the same platform, with only one or two parts that might vary between models in the series. You present a manufacturing processing scenario for the country of origin determination of the vacuum cleaners. Under the scenario, there are approximately 44 components and sub-assemblies used in the NEU700 Series. Parts and components are sourced from both China and Vietnam. The parts and components manufactured in Vietnam include the housing assembly crevice tool, detachable handle, dust cup assembly, lower housing cover, hepa cover, motor cover, motor front cover, front cover, air plate, packaging and packing materials, etc. The parts and components imported from China are combine suction brush, connector wand, nozzle assembly, handle assembly, hepa assembly, motor assembly, printed circuit board, power cord, main wire harnesses, etc. The production process in Vietnam is described as follows: The proposed production scenario consists of both the production of five of the unit’s key sub-assemblies, i.e., dust cup sub-assembly, floor brush sub-assembly, nozzle sub-assembly, handle hose sub-assembly, body sub-assembly and the unit’s final assembly using the materials and components sourced from both China and Vietnam. The production of key components and the final assembly process occur at Midea’s facilities in Vietnam. The workers involved in the production of the vacuums in Vietnam include electricians, product engineers, test engineers, and individuals specially trained to ensure the product’s quality and specifications. The dust cup sub-assembly consists of 8 different process steps, each step involves 2 to 3 sub-steps totaling 29 sub-steps. The steps include the following operations: to install the sealing rings, install the lower cover of the dust cup, assemble the separator, affix cyclone cone, install the cyclone cone, install the handle covers, install the middle cover, and install the upper cover of the dust cup. The floor brush sub-assembly consists of 13 different processing steps, each step involves 1 to 3 sub-steps totaling 26 sub-steps. The steps include the following operations: to thread the steering joint, assemble floor brush, solder male plug, install floor brush covers, install bottom cover wheels, affix spring cover, install decorative covers on the big wheels, assemble the big wheels, install bearings on roller drive block, install motor bracket, install bearings on drive side end cover, install connecting rod, and affix drive side end cover. The nozzle sub-assembly consists of 14 different processing steps, each step involves 2 to 3 sub-steps totaling 29 sub-steps. The steps include the following operations: to install nozzle shrapnel, install the raising shelf, install the large rollers, install the roller brush, install the lower cover of the nozzle, and pack the nozzle. The handle hose sub-assembly consists of 16 different processing steps, each step involves 1 to 5 sub-steps totaling 38 sub-steps. The steps include the following operations: to weld male socket to hose, attach the cannula encapsulation component, install the handle, install the female plugs and plug-in wires, install substrate cables, solder printed circuit board, cut the soldering tip and glue the printed circuit board, install printed circuit board, install the handle cover, install the hose hanger, install the lower handle cover, conduct high and low speed testing, install right and left handle decorative covers, install button and front handle cover, perform testing on leakage and floor brush hose lock installation, and inspect and pack the sub-assembly. The body sub-assembly requires 8 different processing steps, each step involves 2 to 5 sub-steps totaling 26 sub-steps. The steps include the following operations: to install the air duct, install switch bracket assembly, install switch bracket assembly, install the cable, assemble the hose connector, connect the front and rear body components, install the hose connector assembly, and affix the upper cover of the body. The final assembly process consists of combining sub-assemblies and components, and performing testing/inspection. It involves 23 different steps and a total of 40 sub-steps. The steps include the following operations: to install the motor sealing ring and pressure seat, install the motor patch cord, place the motor, install the upper cover of the motor, affix the upper cover, position motor inner cover and affix outer motor cover, affix pressure plate, install the printed circuit board, secure wire connectors, connect drive cables, affix lower body cover, and then conduct the high voltage insulation test, performance test, and nozzle test. Inspection and packing are followed. 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”. In order to determine whether a substantial transformation occurs when components of various origins are assembled into completed products, CBP considers the totality of the circumstances and makes such determinations on a case-by-case basis. The country of origin of the item’s components, extent of the processing that occurs within a country, and whether such processing renders a product with a new name, character, and use are primary considerations in such cases. Additionally, factors such as the resources expended on product design and development, the extent and nature of post-assembly inspection and testing procedures, and worker skill required during the actual manufacturing process will be considered when determining whether a substantial transformation has occurred. No one factor is determinative. Based on the information submitted, the components and parts are imported into Vietnam where they are manufactured into different subassemblies, which are ultimately assembled into the subject vacuum cleaners. We find that the processing performed in Vietnam with respect to the vacuum cleaners in the scenario does constitute a substantial transformation of the imported components and parts into "products of" Vietnam. The manufacturing process in Vietnam transforms the non-originating components and parts to produce the finished vacuum cleaners. It creates a new and different article of commerce with a distinct character and use that is not inherent in the components imported into Vietnam. Therefore, it is of the opinion of this office that the country of origin for the vacuum cleaners will be Vietnam. 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