The country of origin of a pet bed

N350678 July 15, 2025 OT:RR:NC:N4:422 CATEGORY: Origin Mr. Oscar Palacios C.H. Robinson International 180 East Ocean Boulevard Long Beach, CA 90802 RE: The country of origin of a pet bed Dear Mr. Palacios: In your letter dated June 13, 2025, on behalf of your client, Gale Pacific USA, Inc., you requested a country of origin ruling. This ruling is part of a split ruling request. The other portion of the request was assigned Ruling Number N348865. This ruling covers only the pet bed. The merchandise under consideration is described as a pet bed. The bed is a square-shaped iron frame with four tube legs and plastic end caps elevated several inches above the ground. The bed features a square textile panel permanently affixed to each side of the frame. The small bed measures approximately 35 inches long by 22 inches wide by 8 inches high. The medium bed measures approximately 42 inches long by 25.5 inches wide by 8 inches high. The large bed measures approximately 51 inches long by 31.5 inches wide by 8 inches high. The extra large bed measures approximately 59.8 inches long by 37 inches wide by 8 inches high. You have provided the following list of materials and manufacturing steps for four scenarios. Scenario One Materials of Thailand Origin: HDPE (High-Density Polyethylene) is shipped to China to make the woven fabric. Materials of Chinese Origin: the woven fabric, metallic, and plastic components are shipped to Vietnam. Materials of Malaysian Origin: raw iron ingots are shipped to Vietnam. In Vietnam, the ingots are used to create the iron tubes and cassettes. The fabric is cut and sewn to the size of the pet bed. The iron tubes and cassettes are cut to size for the finished good. Scenario Two Materials of Thailand Origin: HDPE is shipped to China to make the woven fabric. Materials of Chinese Origin: Woven fabric is shipped to Vietnam. Materials of Malaysian Origin: Raw iron ingots, metallic and plastic components are shipped to Vietnam. In Vietnam, the production facility uses the ingots to produce the iron tubes, cassettes, and remaining iron components. The fabric is cut and sewn into the size of the pet bed. The iron tubes and cassettes are cut to size for the finished good. Scenario Three Materials of Thailand Origin: HDPE is shipped to China. Materials of Chinese Origin: Yarn created from HDPE resin, metallic, and plastic components are shipped to Vietnam. Materials of Malaysian Origin: Raw iron ingots are shipped to Vietnam. In Vietnam, the yarn is woven into the HDPE fabric. The fabric is cut and sewn into the size of the pet bed. The iron ingots are used to make iron tubes and cassettes, and they are cut to size for the finished good. Scenario Four Materials of Thailand Origin: HDPE is shipped to China. Materials of Chinese Origin: Yarn created from HDPE resin is shipped to Vietnam. Materials of Malaysian Origin: Raw iron ingots are shipped to Vietnam. Materials of Vietnamese: Metallic and plastic components. In Vietnam, the facility manufactures the iron tubes, cassettes and additional components. The yarn is used to produce HDPE fabric that is used for the pet bed. The fabric is cut and sewn to size. The iron ingots produce the iron tubes and cassettes, and they are cut to the pet bed size. 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 reviewed the provided assembly process flow charts and is of the opinion that the Thailand, Chinese, and Malaysian components undergo processing in Vietnam that are sufficiently complex and meaningful as to result in a substantial transformation, such that these components lose their individual identities and become an integral part of a new article, possessing a new name, character, and use. In addition, essential parts are manufactured in Vietnam. Thus, from the details submitted, we agree that the country of origin for the pet bed with all four scenarios, 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 (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 Dana L. Giammanco at dana.l.giammanco@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division