The country of origin of a microwave hood combination

N350470 July 17, 2025 OT:RR:NC:N4:410 CATEGORY: Origin William Baldwin Cassidy Levy Kent (USA) LLP 2112 Pennsylvania Avenue NW, Suite 300 Washington, DC 20037 RE: The country of origin of a microwave hood combination Dear Mr. Baldwin: In your letter dated June 20, 2025, on behalf of your client Whirlpool Corporation, you requested a country of origin determination ruling for a microwave hood combination for the purposes of applying current trade remedies under Section 301. The microwave hood combination is an electric kitchen appliance that combines the functions of a microwave oven and a range hood (also known as a vent hood) into a single unit. It is typically installed above the cooktop and combines the convenience of microwave cooking with the ventilation necessary for removing smoke, steam, and odors from the cooking process. The microwave hood combination consists of the following key assemblies or components: a bottom plate assembly, printed circuit board assembly (PCBA), high voltage (HV) transformer, magnetron, control panel assembly, door assembly, cavity, and an outer wrapper assembly. You summarize the significant steps for producing the microwave hood combinations as the following: Manufacture of Outer Wrapper Assembly The production of the outer wrapper assembly occurs in Mexico. Production of the outer wrapper begins with cutting blank sheet steel to the required size. The cut portions are then stamped in four steps: (1) deep draw; (2) punching and bending; (3) creating a 45-degree flange on a portion of the outer wrapper; and (4) pressing certain portions of the wrapper so that they are flat. This work, which incorporates four stamping dies, is performed while the material proceeds through the stamping machine line. After these steps, rivets are inserted into the outer wrapper assembly using a riveting machine. Next, using a bending machine, the outer wrapper is bent from a generally flat shape (as stamped) to a “U-shape” to take the basic shape of three sides of the microwave oven. Finally, the assembly proceeds to the painting production line, where powder coating in the desired color is applied to the surface in four steps: (1) pre-degreasing; (2) degreasing; (3) rinsing; (4) applying a protective nano-ceramic coating to the wrapper; (5) re-rinsing; (6) drying; (7) cooling; (8) applying the powder coating; (9) curing; and (10) final cooling. Once these steps are complete, the outer wrapper is ready for installation during the microwave assembly process. Manufacture of Bottom Plate Assembly The production of the bottom plate assembly occurs in Mexico. Similar to the outer wrapper assembly, producing the bottom plate assembly begins with cutting blank sheet steel to size. The cut pieces are then stamped in five steps: (1) deep draw; (2) cutting and bending; (3) additional cutting and bending; (4) creating a flange on a portion of the outer wrapper; and (5) pressing the bottom plate assembly flat. Finally, the bottom plate assembly is powder coated using the same 10 steps described above in connection with the outer wrapper assembly. Manufacture of Door Assembly, Including Door Glass The production of the door assembly occurs in Mexico. The door glass is made in Mexico. The remaining door assembly components are made in China. After the imported components are inspected, the glass is inserted into the “door frame with stainless steel cladding assembly.” In this step, the door handle and steam protection plate are also attached to the door frame with stainless steel cladding assembly and door glass. Next, the metal door assembly with inner foil is pressed into the assembly consisting of the aforementioned components, and door hooks are installed. Finally, the inner frame is installed into the door assembly, which at this point is ready for assembly into the finished microwave. Manufacture of PCBA The PCBA is produced using surface mount technology (SMT) in Mexico, in which the electrical components are inserted into a bare printed circuit board, and then soldered to the board and encapsulated in a complex, multistage process. Final Assembly of Subassemblies and Components into Finished Microwave The final assembly, also occurred in Mexico, involves assembling the subassemblies and components into the finished microwave involves 36 distinct steps, including various testing. You present the following two manufacturing scenarios: Scenario 1 The following key components in Scenario 1 will be produced in Mexico: Outer wrapper assembly will be fabricated from sheet steel Bottom plate assembly will be fabricated from sheet steel PCBA will be produced using SMT The door assembly will be produced in Mexico using Mexico-origin glass and other components The following key component will be produced in Thailand: High Voltage Transformer The following key components will be produced in China: Magnetron Cavity Control panel (not including PCBA) The remainder of the components will be produced in China. Scenario 2 Scenario 2 involves the same facts as Scenario 1, with the following exception: The high voltage transformer will be manufactured in China, not in Thailand. The magnetron will be made in Thailand, not in China. When determining the country of origin for purposes of applying current trade remedies under Section 301, 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). We find that, in both scenarios, the foreign components and materials are imported into Mexico where they are manufactured into different subassemblies, and then ultimately assembled into the microwave hood combination. Further, a number of the key assemblies and components are made in Mexico. The manufacturing process, including the SMT process, is complex and meaningful. The manufacturing process in Mexico does create a new and different article of commerce with a distinct character and use that is not inherent in the components imported into Mexico. Therefore, the country of origin of the microwave hood combination is Mexico for both scenarios, and the China Section 301 remedies do not apply. 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