The country of origin of microwave ovens from Vietnam

N352527 September 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 microwave ovens from Vietnam Dear Mr. Bolin: In your letter dated August 17, 2025, you requested a country of origin ruling on microwave ovens on behalf of your client, Midea Consumer Electric (Vietnam) Co., Ltd (“MVN”). The products under consideration are described as the “MVN P02 Solo Function Microwave Ovens”, which covers three models, i.e., MVN model numbers EM9P02, AM9P02 and EM9P02-Kit. The MVN P02 Microwave Ovens heat and cook food by exposing the food to electromagnetic waves. To heat or cook the food, users set the required heating/cooking time based on the type of food ingredients being used. Except for the minor variations on the color, accessories and features all such units will use the same platform and share the same production process. You indicate that they are intended for household use and will be packaged for sale to individual consumers. You state in your letter that the microwave ovens are manufactured in Vietnam through a three-stage process. In the first stage, key components are manufactured in Vietnam using various raw materials. Specifically, MVN will manufacture in Vietnam the base plate, front plate, top plate, U-shaped plate, rear plate, door frame and outer case of the MVN P02 Solo Function Microwave Ovens and the trim decoration and wind guide cover of the EM9P02-Kit model from hot-dip galvanized steel sheet, steel plate, and cold rolled carbon steel. Further, MVN will manufacture in Vietnam the door gasket from polypropylene. In the second stage, MVN manufactures in Vietnam the control panel subassembly, door subassembly, cavity subassembly, base plate subassembly, fan subassembly and lamp subassembly. Finally, in the third stage, MVN conducts the assembly in Vietnam, followed by testing and packaging of each MVN P02 Solo Function Microwave Oven. The first stage involves two phases: (1) The production of metal parts: base plate, front plate, top plate, U-shaped plate, rear plate, door frame and outer case of the MVN P02 Solo Function Microwave Ovens and the trim decoration and wind guide cover of the EM9P02-Kit model are produced in Vietnam from Chinese-produced steel materials by stamping and similar working techniques. (2) The production of the door gasket of the MVN P02 Solo Function Microwave Ovens is produced in Vietnam from Chinese-produced plastic raw materials by an injection molding process. The second stage involves the production of multiple subassemblies in Vietnam including the control panel subassembly, door subassembly, cavity assembly, base plate subassembly, fan assembly, and lamp assembly. The control panel subassembly is comprised of the control panel, control panel housing (or metal control decoration), power printed circuit board (“PCB”) and control membrane. The door subassembly is comprised of the door panel, door frame, door gasket, door glass, door handle, and other components. The cavity subassembly is comprised of the front plate, U-shaped plate, back plate, top plate, turntable motor bracket and waveguide bracket. The base plate subassembly is comprised of the base plate, door lower hinge, rubber feet, high-voltage diode, capacitor holder and high-voltage capacitor. The fan subassembly is comprised of the shaded-pole motor, plastic fan, plastic fan bracket, and noise filter. The lamp subassembly is comprised of the integrated lamp and lamp bracket. In the final stage, the metal and plastic parts are produced in Vietnam, along with the subassemblies manufactured in Vietnam, and the remaining parts from Vietnam and China, will be placed on the main assembly line to produce the finished microwave ovens. It will then be tested, inspected, and packaged. 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. This office has reviewed the provided assembly process flow charts 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. Thus, from the details submitted, we agree that the country of origin for these Microwave Ovens, will be Vietnam. 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) Denise Faingar Acting Director National Commodity Specialist Division