The country of origin of rice cookers

N353911 October 15, 2025 OT:RR:NC:N4:410 CATEGORY: Origin Xinjun Ni Midea Consumer Electric (Vietnam) Co., Ltd. NA2 Street, Thoi Hoa Industrial Park, Thoi Hoa Ward Ben Cat Town, Binh Duong Province Vietnam RE: The country of origin of rice cookers Dear Mr. Ni: In your letter dated September 18, 2025, you requested a country of origin determination ruling on the rice cookers for the purposes of applying current trade remedies. The merchandise under consideration is rice cookers, which will be sold individually in a single, packaged unit. There are three different models of the rice cookers under consideration. You state that the differences among the three models are limited to minor variations in the appearance of the display and functions of the circuit boards. As these three models of the rice cooker are highly similar in terms of use, craftsmanship, and structural assembly, they will be referred to as the same rice cookers for the purposes of this ruling request. You present that the rice cookers each consist of the following components: An inner pot, a main control board, display panel, which will be made in Vietnam; and heat plate / electric hot tray assembly, control panel, thermostat assembly, upper lid sensor assembly, sealing ring and condensation collector, which will be imported from China. The rice cookers are manufactured in Vietnam through a four-stage manufacturing process where some materials or components are sourced from China and some are made in Vietnam, with final assembly taking place in Vietnam. You further state that the production operations in Vietnam require the involvement of product engineers, production technicians, equipment engineers, and process quality inspection engineers. The four stages of the manufacturing process are summarized below: Stage 1: Manufacturing of plastic components in Vietnam The factory produces the plastic components of the rice cookers in Vietnam using raw materials (plastic pellets through plastic injection molding). This manufacturing operation applies to the following parts: water box holder, condensation collector, bottom housing, wire lock mounting plate, handle cover, handle guide, opening buckle plate, inner cover, steam valve, surface cover, outer casing cover, steamer, serving spatula, soup ladle, control box, circuit board bracket, measuring cup, and insulation pad. Stage 2: Manufacturing of hardware components in Vietnam The factory produces major (metal) hardware components of the rice cookers in Vietnam. These hardware components include the heat preservation base plate, exterior pot, casing, and inner pot. The operation involves metal stamping, forming, stretching, trimming, curling, punching, and painting/coating. Stage 3: Circuit board production in Vietnam The factory produces the circuit boards for the rice cookers in Vietnam. First, workers use automatic insertion (AI) and radial insertion (RI) devices to assemble horizontal and vertical electronic components on the circuit board surface. Next, surface mount technology (SMT) mounting equipment is used to mount SMT electronic components on the bottom of the circuit board. Next, workers manually insert hand-inserted components on the circuit board surface and spray the production batch numbers. After electronic components are inserted into the circuit board, they are all welded and fixed by passing through the wave soldering tin furnace. Workers manually repair and weld all defective wave-soldered circuit boards with the soldering iron. Automatic optical inspection, in-circuit test, and functional circuit test devices are used to test the components and functions of the circuit board. Waterproof, dustproof, and corrosion-resistant coatings are applied to the sides of the circuit board with a coat spraying machine and are then dried. Finally, a general inspection is conducted through visual inspection, trimming the edges, and packaging. Stage 4: Final assembly in Vietnam After the previous stages of the manufacturing operations, the components or subassemblies will then be sent to the main assembly line to produce the finished rice cookers, which consists of thirty nine distinct steps, divided into three main sections: a) assembling, b) testing, and c) packaging. 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 manufacturing process information and is of the opinion that the Chinese components undergo processing in Vietnam which results 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, certain essential parts are manufactured in Vietnam involving the operations of SMT, plastic injection molding, etc. Accordingly, from the details submitted, we agree that the country of origin for the rice cookers 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division