The country of origin of an air fryer

N346397 March 25, 2025 OT:RR:NC:N4:462 CATEGORY: Origin Nate Bolin K&L Gates LLP 1601 K Street, N.W. Washington, DC 20006 RE: The country of origin of an air fryer Dear Mr. Bolin: In your letter dated March 1, 2025, you requested a country of origin ruling on an air fryer on behalf of your client, Midea Consumer Electric (Vietnam) Co., Ltd (“MVN”). The product under consideration is described as the “MVN Air Fryer VIII,” model number MF-CY55MS1. This air fryer is a domestic electric countertopdevice that cooks food by circulating hot air around the ingredients using fan blades. The air fryer is manufactured in Vietnam through a three-stage process. The first stage involves three phases: Phase One involves the production of the structural body and other plastic components (e.g., the bottom cover, motor cover, power box, heat insulation block, internal base plate bracket, injection molded upper housing, injection molded lower housing, ring rail, injection molded front bucket cover, air outlet window, control panel bracket, left and right windshield brackets) by an injection molding process. The plastic raw materials are sourced from Vietnam, Thailand, Cambodia, and China. Phase Two involves the production of the metal parts, including the internal base plate, sheet metal upper housing and lower housing, edge trim (or surrounding wall), reflecting cover and sheet metal front bucket cover from steel coiled materials. The fabrication will be completed in Vietnam from steel sourced from either Vietnam or China. Phase Three involves the production of the heating pipe or heating element is manufactured by a third-party supplier of MVN in Vietnam from various raw materials. In the next stage, the display and power boards are manufactured by a third-party supplier in Vietnam from various raw materials. In the final stage, also performed in Vietnam, the Vietnamese-origin body and other plastic and metal components will be placed with the remaining components originating from Vietnam, China, and Thailand on the main assembly line to produce subassemblies (e.g., the bucket and base subassemblies) followed by final assembly of the finished MVN Air Fryer VIII. It will then be tested, inspected, and packaged. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (?HQ?) H301619, dated November 6, 2018. 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, 681 F.2d 778 (C.C.P.A. 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). This office reviewed the provided assembly process flow charts and is of the opinion that the Chinese components undergoes processing, which is sufficiently complex and meaningful as to result in a substantial transformation, such that the non-originating components lose their individual identities and become an integral part of a new article, possessing a new name, character, and use. In addition, essential parts are manufactured in Vietnam. Thus, from the details submitted, we agree that the country of origin for the ?MVN Air Fryer VIII,? model number MF-CY55MS1 will be Vietnam. 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.?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 CFR 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 Sandra Sary at sandra.sary@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division