The country of origin of wire fan heaters

N351503 August 15, 2025 OT:RR:NC:N4:410 CATEGORY: Country of Origin Nate Bolin K&L Gates LLP 1601 K Street, N.W. Washington, DC 20006 RE: The country of origin of wire fan heaters Dear Mr. Bolin: In your letter dated July 20, 2025, on behalf of your client Midea Consumer Electric (Vietnam) Co., Ltd. (“ MVN”), you requested a country of origin determination ruling for wire fan heaters for the purposes of applying current trade remedies. The items under consideration are wire fan heaters model numbers NF15-24UR (customer model numbers MSH23FT3DSB and SH23FT3DSBV) and NF15-24URC (customer model numbers PSH24FT4DMB and PSH24F4DABV). The NF15 fan heaters are for household use and packaged individually in single, packaged units. The NF15 fan heaters are a fan/space heater combination that can generate heat and create airflow by moving air (without generating heat). As space heaters, the NF15 fan heaters operate by generating heat through a heating wire, while the motor drives the fan blades to blow the heat out of the casing. The fan blades in the NF15 fan heaters then circulate the heated air to the room or other surrounding area where the NF15 fan heaters are located. Except for the minor variations on certain accessories and the base design, all such units will use the same platform and share the same bill of materials and production process. You present the following manufacturing process scenario, in which the NF15 fan heaters are manufactured in Vietnam using raw materials and components originating from both Vietnam and China. The NF15 fan heaters are produced in Vietnam through a manufacturing and assembly process comprising three main stages. In the first stage, key components are manufactured in Vietnam from various raw materials. Specifically, MVN in Vietnam uses injection molding techniques to manufacture the decorative piece, decorative ring, right side panel, base, lampshade, fan blade, back shell, front shell, bottom cover, top cover, fireproof box, left side panel, and cover plates for the NF15 fan heaters. Next, in the second stage, a third party in Vietnam manufactures the heating wire of the NF15 fan heaters at its facility in Vietnam. Finally, operations performed in the third stage of the manufacturing process include the installation of the Vietnam-origin heating wire, decorative piece, decorative ring, right side panel, base, lampshade, fan blade, back shell, front shell, bottom cover, top cover, fireproof box, left side panel, and cover plates, the installation of the Chinese-origin power circuit board, motor and temperature sensor (among other components) into the NF15 fan heaters, as well as the testing and packaging of the finished product. 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). This office reviewed the provided assembly process flow charts and other materials in the submission, and is of the opinion that the Chinese components undergo processing in Vietnam that is 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. Accordingly, from the details submitted, we agree that the country of origin for the NF15 fan heaters 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 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