The country of origin of an air inflator

N351505 August 7, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Elieen Chen Talway Vietnam Company Limited T-2-1-1 and T-2-1-2, Que Vo Industrial Zone (Extension Area) Nam Son Ward, Bac Ninh Province Bac Ninh City, 16000 Vietnam RE: The country of origin of an air inflator Dear Ms. Chen: In your letter dated July 20, 2025, you requested a country of origin ruling on an air inflator. Descriptive information was provided with the submission. The Air Inflator, part number DL321-HD, is described as a device used to inflate tires, sports equipment, air mattresses and other inflatable items. The rectangular shaped inflator is portable and features a digital display, SOS technology, LED lights, a type C charging port, a power cord port and a USB-A output port. The portable inflator will be imported packaged with accessories (three nozzles, a replacement fuse, an air hose, and a power cord). With respect to origin, the final assembly of the inflator occurs in Vietnam using components from China and Vietnam. Prior to the final assembly, the plastic front and rear cases of the inflator are formed in Vietnam and the printed circuit board assembly (PCBA) is produced by soldering Chinese components onto a motherboard. The internal air cylinder of the inflator is also assembled in Vietnam, which begins by die casting a bracket and afterwards riveting a bearing to this bracket. Then, a gear with a bearing is installed onto the motor from China, which is followed by the installation of a Chinese sourced rod with a leaf spring. Next, a larger gear with a bearing is installed and locked onto the cylinder, and a connecting rod with a bearing is connected to the bracket. The final assembly of the inflator begins by soldering the air pump. A button, the PCBA, and the LED light are installed, followed by the installation of the air cylinder bracket. Wiring of the air cylinder is connected, and the cylinder is soldered in place. Afterwards, an air hose and an air pump are installed. The rear case is then connected to the front case and screwed in place. Upon completion, each inflator undergoes testing and inspections, and is packaged with Chinese sourced accessories. When determining the country of origin for purposes of applying current trade remedies under current trade remedies 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). CBP has held that whether an assembly process is sufficiently complex to rise to the level of a substantial transformation is determined upon consideration of all the operations that occur within that country. Here, components are assembled together in Vietnam to produce a motorized air cylinder and a PCBA, which are combined with other components, such as Vietnamese manufactured front and rear cases, to form an air inflator. When considering the totality of the circumstances, this office finds that the assembly processes that occur in Vietnam, taken as a whole, are sufficiently complex and meaningful as to result in a substantial transformation, such that the non-originating components lose their individual identities and become an integral part of a new article, possessing a new name, character and use. Based on the processes described in the submission, we find the country of origin of the air inflator is 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 Sandra Martinez at sandra.martinez@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division