The country of origin of an electric fireplace from China.

N347396 April 29, 2025 OT:RR:NC:N4:415 CATEGORY: Origin Stacia Keegan RIM Logistics 1303 Jack Court Barlett, IL 60103 RE: The country of origin of an electric fireplace from China. Dear Ms. Keegan: In your letter dated April 3, 2025, you requested a country of origin ruling on behalf of your client, GHP. The product under consideration is described as the “AF-02 Electric Fireplace.” It is an electric fireplace that includes a heater with fan and features decorative logs and a light emitting diode (LED) produced flame effect that provides the appearance of a burning fire. This fireplace insert is assembled in Malaysia from parts sourced from Malaysia and China. We note that several of the key components such as the heater tube, thermostat, motor, and control components are sourced from China. 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). In order to determine whether a substantial transformation occurs when components 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/manufacturing operations that are minimal will generally not result in a substantial transformation. This office reviewed the submitted production process, which is relatively minor and as it is a simple assembly process, it would not amount to a substantial transformation of the Chinese parts in Malaysia. Further, based on the parts breakdown and technical narrative submitted in your request, it is the opinion of this office that the Chinese parts, including the heater tube, thermostat, and motor, impart the essential identity and functionality to this electric fireplace.? As such, we hold the opinion that the country of origin for this product is China. 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 Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division