The tariff classification and country of origin of metal hanging decor

N351656 August 13, 2025 CLA-2-83:OT:RR:NC:N5:121 CATEGORY: Classification; Origin TARIFF NO.: 8306.29.0000; 9903.02.69 Sarah Chen Sunlight Import and Export Company, Ltd. 5/F Hong Kong Trade Centre, 61-167 DesVoeux Road Central, Hong Kong, Hong Kong China RE: The tariff classification and country of origin of metal hanging decor Dear Ms. Chen: In your letter dated July 24, 2025, you requested a tariff classification and country of origin determination ruling. The article under consideration is described as Metal Hanging Décor AST. The décor is made of stamped 0.4mm galvanized iron and depicts four different designs - a bird, a snail, a butterfly, and a ladybug. Each design has one or two small holes drilled in at the top and a jute string for hanging purposes. You state these items are intended as decoration during the spring season. The applicable subheading for the Metal Hanging Décor AST will be 8306.29.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Bells, gongs and the like, nonelectric, of base metal; statuettes and other ornaments, of base metal; photograph, picture or similar frames, of base metal; mirrors of base metal; and base metal parts thereof: Statuettes and other ornaments, and parts thereof: Other. The general rate of duty will be Free. You present a manufacturing scenario in which the raw galvanized iron is purchased in China and shipped to Vietnam. In Vietnam the iron is stamped into the four designs, sprayed with transparent oil, and a jute string is attached. The décor is then packaged for export to the United States. The oil, jute, and packaging materials are all of Vietnamese origin. 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). Regarding the country of origin of the Metal Hanging Décor AST it is our view that raw iron is substantially transformed in Vietnam into finished hanging decor. As demonstrated in your production process, all stamping and finishing operations occur in Vietnam. It is therefore the opinion of this office that country of origin of the Metal Hanging Décor AST is Vietnam. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of Vietnam will be subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.69, in addition to subheading 8306.29.0000, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. 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 Jennifer Jameson at jennifer.d.jameson@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division