The country of origin of fans

N351782 August 27, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Roman Campos Muncy, Geissler, Olds & Lowe PC 125 S. Royal St. Alexandria, VA 22314 RE: The country of origin of fans Dear Mr. Campos: In your letter dated July 29, 2025, you requested a country of origin ruling on behalf of your client, Jiangmen Lingfeng Electric Appliances Manufacturing Co., Ltd., to apply current trade remedies and for marking purposes. Information describing the assembly processes was submitted for review. The products at issue are a 20" Floor Fan (model number SFC1-500B), a 20" Shroud Fan (model number SFDE-500B3-1), a 16" Pedestal Fan (model number SFSR3-400CPT) and a 24" Drum Fan (model number SFDC2-600T). Each fan is primarily comprised of a power cord, electrical components, a motor, and fan blades that are encased in protective front and rear grilles. Certain models feature casters and a pedestal that consists of a tube with a base. With respect to origin, the final assembly occurs in China and consists of components from China and Thailand. Prior to the final assembly, fan blades are manufactured in Thailand using cutting, stamping and shaping processes. The motors used to power the four fan models are also assembled in Thailand using components sourced from Thailand. The remainder of the components are manufactured in China. To assemble the 20" shroud and floor fans, four interfaces of the switch are soldered to lead wire. An upper bracket is assembled to a spring, and lead wires are connected to a power cord, a motor and a capacitor. A motor switch flange and switch knob are then installed, and ground wires are connected. Afterwards, a switch cover and an upper bracket are mounted to a motor, which is subsequently installed and screwed into a rear grille. A fan blade holder, a fan blade sleeve and fan blades are riveted to each other, and the fan blade assembly is then screwed onto the motor. Next, a shroud is secured to the rear grille, and finally, rubber legs are assembled to a bracket, and a front grille is joined to the shroud using screws. Once complete, tests and inspections are conducted. For the 24" drum fan, four interfaces of the switch are soldered to lead wire. A motor is mounted on a rear grill and screwed in place. Next, a motor back plate is glued to a switch knob and rubber feet are screwed in place. Casters and a drum body are installed. The fan blade holder, a fan blade sleeve and fan blades are riveted to each other, and the fan blade assembly is screwed onto the motor. The front and rear grilles are mounted to a shroud and screwed in place. Once complete, tests and inspections are conducted. For the 16" pedestal fan, a motor is screwed onto a front cover. Next, a fork cover, shaft sleeve and connecting rod are joined using screws. A switch is then assembled to wires, and the lead wire of the motor is connected to a power cord. A switch is mounted to a rear cover, a gearbox and a fork subassembly are screwed in place. The required knobs are screwed in place, and a front grille is mounted to a rear grille. A fan blade holder, a fan blade sleeve and fan blades are riveted to each other. The fan blade assembly is screwed onto the motor, and the grilles are secured. Finally, an upper tube is installed and locked into the lower tube and then a base. Once complete, tests and inspections are conducted. When determining the country of origin for purposes of applying 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (CBP) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Here, the final assembly processes that occur in China are rather simple and do not constitute a substantial transformation. The final assembly processes performed in China do not change the shape, character or predetermined use of the inputs, as the processes are not particularly complex. The assembly steps consist of mounting fan blades to a motor, which are joined or fastened to other components using screws. As such, we look to the origin of the motor and the fan blades, as these components are the essential components of the four fans. Therefore, as the origin of the motor and the fan blades is Thailand, the origin of the four fans is Thailand. 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