The country of origin of three space heaters.

N347421 April 22, 2025 OT:RR:NC:N4:415 CATEGORY: Origin Cayce Johnson Dollar General 100 Mission Ridge Goodlettsville, TN 37072 RE: The country of origin of three space heaters. Dear Ms. Johnson: In your letter dated April 3, 2025, you requested a country of origin ruling. There are three products under consideration, and they are all household, fan-forced space heaters. The first item is described as the “Milk House Compact Utility Heater,” SKU number 36672401-GF. It is an up-right heater in a steel housing. You indicate the temperature and fan speed can be controlled by the user via the knobs on the front and that this apparatus can be used in a fan-only mode without the heat. Your submission states that in this production scenario the motor, switches, fan, and heating element are from China. The metal housing and grill is diecast by the manufacturer in Cambodia from raw materials procured in Cambodia. The power cord, nuts, and bolts are also from manufacturers in Cambodia. The assembly of this heater takes place in Cambodia. The second item is an alternative version of the above “Milk House Compact Utility Heater,” with SKU number 36672401-RE. Your submission states that in this production scenario the heater will be sourced from Vietnam. The heating element will be produced in Vietnam from raw materials also procured from Vietnam. The metal housing, grill, and tip over switch are of Chinese origin. In Vietnam, the top handle and fan blades are formed, as well as all the plastic items are injection molded, to include the feet, brackets, knobs, light covers, etc. The motor, thermostat, power cord, nuts, and bolts are all from various manufacturers in Vietnam. The final product assembly takes place in Vietnam. The third item is described as the “Convertible Heater Fan,” SKU number 33087201-TE. It is a small heater in a plastic housing with the temperature and fan speed controlled by the user via the knobs on the front. It can also be used in a fan-only mode without the heat. For this space heater, the manufacturer in Vietnam is only assembling the components to form the final product. The housing, heating element, motor, and power cord are procured from Vietnamese manufacturers. The fan blades, switches, and thermostat have been procured 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 assembly process for the three product scenarios. We note simple assembly of the assorted space heater components would not constitute a substantial transformation due to it not being sufficiently complex and meaningful to result in the non-originating components to lose their individual identities and become an integral part of a new article, possessing a new name, character, and use. In the first scenario, it is the opinion of this office that the motor, switches, fan, and heating element, all produced in China, impart the essential identity and functionality to this space heater. Therefore, we find that the country of origin for the “Milk House Compact Utility Heater,” SKU number 36672401-GF, will be China. In the second scenario, you indicate the heating element, fan blades, motor, thermostat, and power cord, along with additional components, will be produced in Vietnam. Similarly, we find that as these parts would impart the essential identity and functionality to this space heater, the country of origin for the “Milk House Compact Utility Heater,” with SKU number 36672401-RE, will be Vietnam. In the third scenario, the housing, heating element, motor, and power cord are sourced from Vietnam and the finished heater will also be assembled in Vietnam. Again, as these components would impart the essential identity and functionality to the space heater, we find that the country of origin for the “Convertible Heater Fan,” SKU number 33087201-TE, 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 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, contact National Import Specialist Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division