The country of origin of a license plate frame

N353979 October 15, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Vincent Liu Olympia Tools International Inc. 929 N Grand Ave Covina, CA 91724 RE: The country of origin of a license plate frame Dear Mr. Liu: In your letter dated September 19, 2025, you requested a country of origin ruling on a license plate frame. The product under consideration is a decorative license plate frame (Item Number 410-025-0136), designed to be placed around a standard automotive license plate. The frame is made of metal and has an opening that allows the license plate to remain visible while covering its edges for decorative purposes. It includes two pre-drilled screw holes that align with standard license plate screw positions. You state that raw sheets of metal sourced from Vietnam are stamped into license plate frame blanks in Vietnam. These blanks are then further formed and bent into the final shape and size of the frame. The semi-finished frames are then shipped to China, where the front and back surfaces are either powder-coated with paint or chrome-plated. No other mechanical processing is performed in China 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 ruling N340470, dated June 25, 2024, this office ruled on a similar scenario, where a license plate holder had undergone similar processes as the license plate frame at issue. We stated that the powder coating with paint or chrome plating performed in China does not substantially transform the frame into a new article with a new name, character or use. Similarly, in this case, the powder-coating with paint or chrome-plating in China will not substantially transform the license plate frame. However, the raw sheets of metal undergo a substantial transformation in Vietnam after being stamped and bent into the final shape. As a result, the country of origin of the license plate frame will 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 Liana Alvarez at liana.alvarez@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division