The country of origin of venetian blinds

N335242 September 27, 2023 OT:RR:NC:N5:113 CATEGORY: Origin Ms. Silvia Hall All Strong Industry USA, Inc. 326 Paseo TesoroWalnut, CA 91789 RE:  The country of origin of venetian blinds Dear Ms. Hall: In your letter dated September 11, 2023, you requested a country of origin ruling on venetian blinds.  Pictures and a description of the manufacturing process were provided with your submission.  The article under consideration is described as a 1” Aluminum Venetian Blind that functions as a window covering.  The finished venetian blind is comprised of aluminum slats, head and bottom rails, a cordless mechanism, and a mounting hardware set.  The subject blind is produced in two countries, Taiwan and China.  The production process begins with extruded aluminum coil that is manufactured in Taiwan.  The aluminum coil is shipped to China to be slit and painted before it is shipped back to Taiwan to be cut and formed into slats.  The head and bottom rails are made of aluminum that is extruded and shaped in Taiwan.  The cordless mechanism consists of a plastic box, plastic components, and a non-visible metal spring inside the cordless mechanism.  The plastic box and plastic components are made in China, and the non-visible metal spring is made in Taiwan.  The mounting hardware includes two metal brackets made in Taiwan, aluminum screws made in Taiwan, and a plastic handle made in China.  All cordless mechanism components/parts are assembled in Taiwan.  The retail packaging labels are printed in Taiwan and the shipping master pack brown cardboard box is made in Taiwan.  The venetian blind is assembled and packaged in Taiwan and shipped from Taiwan to the United States. Regarding your request for the appropriate country of origin of the 1” Aluminum Venetian Blind, 19 C.F.R. § 134.1(b) provides in pertinent part as follows: Country 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 this part. You indicated that the production processes for the 1” Aluminum Venetian Blind performed in Taiwan include assembling the cordless mechanism, inserting the cordless mechanism and operating components inside the head rail, tying the ladder to the head and bottom rails, assembling the aluminum slats into the ladder, hanging the wand on the blind, packing the assembled venetian blind with the mounting hardware set in a retail package, packing the retail packages in the shipping master pack cardboard box, and shipping from Taiwan. 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 Nat’l Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).  However, if the manufacturing or combining process is merely a minor one that leaves the identity of the article intact, a substantial transformation has not occurred.  Uniroyal, Inc. v. United States, 3 CIT 220, 542 F. Supp. 1026, 1029 (1982), aff'd, 702 F.2d 1022 (Fed. Cir. 1983).  Substantial transformation determinations are based on the totality of the evidence. See Headquarters Ruling (HQ) W968434, date January 17, 2007, citing Ferrostaal Metals Corp. v. United States, 11 CIT 470, 478, 664 F. Supp. 535, 541 (1987). To determine whether a substantial transformation occurs when components of various origins 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 operations that are minimal will generally not result in a substantial transformation. Regarding the country of origin for the 1” Aluminum Venetian Blind, it is the opinion of this office that the manufacturing and assembly operations performed in Taiwan substantially transform the slats, head and bottom rails, cordless mechanism, and mounting hardware into a new and different article of commerce with a changed name, character, and use.  Thus, it is the belief of this office that the manufacturing and assembly processes performed in Taiwan result in a substantial transformation of the components, and the venetian blind shipped from Taiwan is a product of Taiwan. 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 the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect.  If 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.  Additionally, we note 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 and Border Protection 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, please contact National Import Specialist Ann Taub at ann.taub@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division