The country of origin of a plush flamingo security blanket

N349315 June 16, 2025 OT:RR:NC:N3:356 CATEGORY: Origin Neo Qian Shanghai Sunwin NO.17, Lane 688, Hengnan Road Shanghai 200000 China RE: The country of origin of a plush flamingo security blanket Dear Mr. Qian: In your letter submitted May 22, 2025, you requested a country of origin ruling. Photographs and a description of the item were received with your inquiry. The subject item is a security blanket with a stuffed flamingo plush toy permanently attached to the center of the fabric, item #SWBP21013. The blanket portion measures 14” x 14” and is too small to be used as an actual blanket. The flamingo has a gray bill, pink wings, and slender legs. The blanket and the flamingo, including its stuffing, are of 100 percent polyester. The item is principally designed for the amusement of babies. COUNTRY OF ORIGIN - LAW AND ANALYSIS: With regard to your request for the appropriate country of origin of the plush security blanket, 19 C.F.R. § 134.1(b) provides in pertinent part as follows: Country of origin means the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of this part. As stated in HQ 735009, dated July 30, 1993, “The country of origin is the country where the article last underwent a ‘substantial transformation’, that is, processing which results in a change in the article's name, character, or use.” The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, and use, different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 69 C.C.P.A. 151 (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 of various origins 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 operations that are minimal will generally not result in a substantial transformation. With respect to the subject item, you state the following: The polyester knit fabric for the flamingo and the top layer of the blanket, and the polyester woven fabric for the bottom layer of the blanket, are sourced from China. Stuffing for the flamingo is sourced from Vietnam. All of these materials are exported to Cambodia. In Cambodia, the knit and woven fabrics are cut and sewn to form the blanket, and the blanket is edged. Also in Cambodia, the flamingo is formed and stuffed, its eyes are embroidered, and the flamingo is sewn to the blanket. Packaging materials, including a hangtag with grosgrain ribbon, a polybag, and a carton, are sourced from Cambodia, and the item is packaged and inspected in Cambodia. Based on the information submitted, the country of origin of the plush flamingo security blanket is Cambodia. 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 C.F.R. 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 Maryalice Nowak at maryalice.nowak@cbp.dhs.gov. Sincerely, (for) Steven A. Mack Director National Commodity Specialist Division