The country of origin of two poured candles from Vietnam.

N351477 August 4, 2025 OT:RR:NC:N4:415 CATEGORY: Origin Cheryl Wynn Dollar General Corporation 100 Mission Ridge Goodlettsville, TN 37072 RE: The country of origin of two poured candles from Vietnam. Dear Ms. Wynn: In your letter dated July 18, 2025, you requested a country of origin ruling. The first product under consideration is described as a candle in a teacup, item number 42358701. It is a 5.30-ounce candle poured into a ceramic teacup with a floral motif. It will be made from paraffin wax, a cotton wick, a metal wick plate, glue, and a finished ceramic teacup sourced from China, palm wax from Indonesia, and fragrance which will be imported from the United States. The dust cover and label are made in Vietnam. The following processes are performed in Vietnam: the paraffin and palm wax slabs are melted and combined with the fragrance, the cotton wick is glued to the wick plate, the wax is poured into the teacup, the completed cotton wick is inserted, and finally, the dust cover and label are attached. The second product under consideration is described as a candle in a pedestal glass vase, item number 42276001. It is a 6.7-ounce candle poured into a red glass pedestal vase. It will be made from wax sourced from Hong Kong, the completed wick from Germany, and the vase, dust cover, and label produced in China. Similar to the processing for the first candle, they will melt the wax, pour the wax into the glass vase, and attach the dust cover and label in Vietnam. 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. We find that a substantial transformation occurs when the wax is poured into the container creating the candle. This is consistent with past precedent, and we refer to New York ruling N016511, dated September 12, 2007, as an example. As that is performed in Vietnam, for both products, we hold the opinion that the country of origin for these poured candles, item numbers 42358701 and 42276001, would 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 CBP Regulations (19 CFR 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 Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division