The country of origin of air fryer toaster ovens from Vietnam.

N347849 May 9, 2025 OT:RR:NC:N4:415 CATEGORY: Origin Nate Bolin K&L Gates, LLP 1601 K Street Northwest Washington, DC 20006 RE: The country of origin of air fryer toaster ovens from Vietnam. Dear Mr. Bolin: In your letter dated April 15, 2025, you requested a country of origin ruling on air fryer toaster ovens on behalf of your client, Midea Consumer Electric (Vietnam) Co., Ltd (“MVN”). The products under consideration are described as the “GTZ Air Fryer Toaster Ovens,” MVN model numbers AC25GTZ-L00ZA and AC25GTZL00EA. These appliances are electric countertop cooking devices that combine an oven with an air fryer and will cook food by heating the ingredients within its interior cavity. It is intended for household use and will be packaged for sale to individual consumers. The first stage involves the production of key components from raw materials originating in Vietnam and China. The bottom rear and top panels, left and right side panels, front panel, enclosure, crumbs tray, baking tray, door liner, and insulating plate are all manufactured in Vietnam from Vietnamese-produced steel materials by stamping and other metal working techniques. The second stage involves the production of subassemblies for this air fry toaster oven including the control panel subassembly, door assembly, and cavity subassembly. The control panel assembly is comprised of the display cover, control panel shell, front panel, computer board bracket, buttons, power board, among other parts. The door assembly is comprised of the oven door frame, the left and right handle bases, door handle, among other parts. The cavity assembly is comprised of the left and right side panels, left and right rollers, the back plate, top plate, fan and motor, among other parts. In the final stage, the Vietnamese-produced metal components and sub-assemblies with the remaining components originating from Vietnam and China will be placed on the main assembly line to produce the finished “GTZ Air Fryer Toaster Ovens.” They 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). 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 provided assembly process flow charts and is of the opinion that the Chinese components undergo processing in Vietnam that is sufficiently complex and meaningful as to result in a substantial transformation, such that these 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 ?GTZ Air Fryer Toaster Ovens,? MVN model numbers AC25GTZ-L00ZA and AC25GTZL00EA, 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 CBP 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