The country of origin of three oven lamps

N350050 July 2, 2025 OT:RR:NC:N4:410 CATEGORY: Origin Long Chen Thai Jiuzhou Electron Co Ltd. 88/152 Moo 15 Bangsaotong Sub-District Bangsaotong 10540 Thailand RE: The country of origin of three oven lamps Dear Mr. Chen: In your letter dated June 11, 2025, you requested a country of origin ruling on three oven lamps for the purposes of current trade remedies. The merchandise under consideration is referred to as Item 1 Wall Oven Lamp (191D7209G007, 191D7209G008), Item 2 Wall Oven Lamp (191D7477G004) and Item 3 Apex Lamp (301D1481G001). The Bill of Materials and the component pictures indicate that the Oven Wall Lamps in Item 1 and Item 2 appear to be highly similar in construction except for the shape of the light head (housing). Each of these oven lamps consists of a glass lens, a metal housing containing a socket, a light bulb and electrical wires with plug or connector at either end. Additionally, Item 2 also has a metal clip. The Apex Lamp (Item 3) consists of a glass lens, metal case (housing), metal pin, light bulb and a socket with two pins for connection to a power supply. The submitted materials indicate that all of the components are of Chinese origin. The components are shipped to Thailand and assembled into the finished lamps. The assembly process for the lamps in Thailand is described as follows: For the Wall Oven Lamps (Item 1 and Item 2) Harness assembly Socket assembly of ceramic and harness Assembly with metal case Assembly with bulb Assembly with lens Testing and packaging For the Apex Lamp (Item 3) Laser welding of the metal case and metal pin Assembly of socket and metal case Assembly with bulb Assembly with lens Testing and packaging When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter 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 regard to the country of origin of the subject lamps, all the components of the lamps are of Chinese origin. The components are imported into Thailand where they are assembled into the finished oven lamps. The components do not undergo a physical change, nor do they change in character as a result of the assembly operations in Thailand. The components have a pre-determined end-use as parts and components of the lamps at the time of importation into Thailand and do not undergo a change in use due to assembly process in Thailand. It is of our view that although certain operations such as laser welding might be complex in some circumstances, we must look at the totality of the facts. Accordingly, the nature of the assembly process for each of the lamps in Thailand is not sufficiently complex or meaningful as to constitute a substantial transformation. The manufacturing process in Thailand does not create a new and different article of commerce with a distinct character and use that is not inherent in the components imported into Thailand. Therefore, the country of origin of the lamps will be China for purposes of current trade remedies. 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 Michael Chen at michael.w.chen@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division