The country of origin of a vaporizer subassembly

N350867 July 16, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Steven Zisser Zisser Customs Law Group 9355 Airway Rd., Suite 1 San Diego, CA 92154 RE: The country of origin of a vaporizer subassembly Dear Mr. Zisser: In your letter dated July 2, 2025, you requested a country of origin ruling on behalf of your client, Juul Labs, Inc. The merchandise under consideration is identified as the Collector Sub Assembly, which you state is a component of the finished JUUL 2 Pod vaporizer device. The subject device is comprised of a resistive heating element and cotton wick encased within a plastic housing. Attached to the plastic housing is a collector, which allows for the e-liquid to flow properly through the finished vaporizer pod. We note that the subject assembly functions as the primary heating element for the vaporizer device. At importation, the sub assembly does not contain an e-liquid reservoir or the electrical elements necessary to vaporize the liquid. In your request, you state that the manufacturing process begins in Vietnam with the creation of the resistive heating element. The heating element is then sent to China where the cotton wick is inserted within a specialized slot on the side of the element. The element and wick are then encased within the plastic housing, upon which the collector is laser welded. The finished device is then packaged for shipment to the United States. 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). Regarding the origin of the subject assembly, it is the opinion of this office that the resistive heating element created in Vietnam imparts the character of the finished device. Further, the assembly process performed in China is simple in nature and does not substantially transform the element into a new and different article of commerce. As such, the origin of the Collector Sub Assembly 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 Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, James Forkan Acting Director National Commodity Specialist Division