The country of origin of a plastic cellphone case from China.

N349310 June 11, 2025 OT:RR:NC:N4:415 CATEGORY: Origin Hyeyeon Lee Spigen, Inc. 8845 Irvine Center Drive, Suite 100 Irvine, CA 92618 RE: The country of origin of a plastic cellphone case from China. Dear Ms. Lee: In your letter dated May 21, 2025, you requested a country of origin ruling on a plastic cellphone case. The product under consideration is described as a mobile phone case, model number ACS06583. It is designed to cover and safeguard a cellphone from physical damage such as scratches, drops, and impacts. This case is made from a combination of polycarbonate (“PC”) and thermoplastic polyurethane (“TPU”) plastic. The case covers the back, sides, and corners of the phone, but not the screen, and has a cutout on the back for the phone’s camera. It also features a built-in kickstand. Per your submission, all components are sourced from China except the protective film and paper packaging which will be produced in Thailand. We note that the TPU resin and PC plate are molded to shape in China. In Thailand, the molded case undergoes further machine processing to create the magnetic slot, the kickstand and magnet are added to the case, protective film is laminated to the case, and it is 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 is of the opinion that the Chinese injection molded plastic components hold the basic nature of the finished case and the further processing performed in Thailand would not result in a substantial transformation as it would not become a new article, possessing a new name, character, or use. Therefore, the country of origin for this mobile phone case, model number ACS06583, will be 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 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, (for) Steven A. Mack Director National Commodity Specialist Division