The country of origin of venetian blinds

N350480 July 2, 2025 OT:RR:NC:N1:164 CATEGORY: Origin Silvia Hall All Strong 950 Raco Drive, Suite F Lawrenceville, GA 30046 RE: The country of origin of venetian blinds Dear Ms. Hall: In your letter dated June 22, 2025, you requested a country of origin ruling on venetian blinds. Manufacturing and product information were submitted with your request. The items under consideration are described as aluminum venetian mini blinds to be used as window coverings. At importation, the assembled venetian blinds contain several components including aluminum slats, aluminum head and bottom rails, cordless mechanisms for opening and closing the blinds, a wand for adjusting the angle of the blinds, and mounting hardware such as metal brackets and screws. In your request, you state that the aluminum slats are slit from aluminum coil and painted in China. Furthermore, a non-visible metal spring component of the cordless mechanism is made in China. In Vietnam, you state that the aluminum head and bottom rails are extruded and shaped, and the plastic components of the cordless mechanism box are assembled with the non-visible metal spring from China. In addition, the metal brackets, plastic mounting components, screws, and packing materials are all made in Vietnam. In your request, you assert that all assembly takes place in Vietnam. After the cordless mechanism is assembled, it is inserted with operating components inside the headrail. Then, the ladder component, which holds the aluminum slats in place, is tied to both the head and bottom rails. At that point, the aluminum slats are placed into the ladder, and the wand is attached to the head rail. Finally, the assembled venetian mini blind is labeled, packaged together in a cardboard box with the mounting hardware and ready for export from Vietnam. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, 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 this case, the manufacturing and assembly operations performed in Vietnam substantially transform the aluminum slats, aluminum head and bottom rails, cordless mechanism, mounting hardware, and other components into an article of commerce with a new name, character, and use. Accordingly, the country of origin of the venetian blinds 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 (C.F.R.), 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 C.F.R. 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 Paul Taylor at paul.m.taylor@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division