The country of origin of propane gas island grills

N354448 October 17, 2025 OT:RR:NC:N4:410 CATEGORY: Origin James Pai BDO USA 600 Anton Boulevard, Suite 500 Costa Mesa, CA 92626 RE: The country of origin of propane gas island grills Dear Mr. Pai: This is in response to your letter dated September 30, 2025, on behalf of your client Nexgrill Industries, Inc., requesting a country of origin determination of gas grills for purposes of current trade remedies. The merchandise under consideration consists of three models of propane gas island grills designed for grilling, griddling, and general food preparation. Photos of the three models are provided in your submission. All three models will be manufactured using substantially identical operations and processes at factories located in Indonesia or Malaysia. The gas grills each consist of a stainless steel lid, firebox, control panel, doors, drawers, side shelves, and a metal cart frame. You present a manufacturing process scenario, in which the factory in either Indonesia or Malaysia assembles the components of both Chinese origin and Indonesian/Malaysian origin to manufacture the gas grills, including the production of certain key sub-assemblies and the final assembly process occurred in Indonesia or Malaysia. Main Lid Production The raw material (steel sheets) is purchased in China. The raw material is shipped to the Indonesia/Malaysian factory, where the sheets are transformed into the middle lid panel through forming, bending, and punching. The lid panel and side panel are then refined through sharp edge grinding and welded into a grill lid and griddle lid. The Chinese-originating accessories (lid handle, badges, and thermometer are prepared to be staged for assembly onto the lid. The completed lid assembly is then staged for pack out. Firebox Production The operation process of the fire boxes is similar to that in the above main lid production. Raw material (sheet steel) is purchased in China then shipped to Indonesia/Malaysia. The Indonesia/Malaysian factory processes the sheet steel into the firebox panels by forming, bending, and punching the raw material. The resulting firebox panels are transformed into the firebox panels through forming, bending, and punching. The firebox panels are then refined through sharp edge grinding. The firebox panels are combined through various welding operations to form a firebox assembly. The firebox assembly will be ready to install the Chinese-originating control panel and install the Indonesia- or Malaysia- originating gas system assembly and to complete sub-assembly and fire testing. Drawer Production Raw material (sheet steel) is purchased in China. The raw material is shipped to a factory in Indonesia or Malaysia, where the sheet steel is transformed into a full drawer through forming, bending, and punching. The stainless-steel drawer front is then refined through sharp-edge grinding. The three-side steel panels and one bottom panel will be prepped for porcelain enamel coating. The Chinese-originating drawer handle is then affixed onto the drawer to form a full functional drawer. Gas Train Assembly Production The gas train components including the manifold tube, regulator hose, fittings, and gas valves, are sourced locally by the factory in Indonesia or Malaysia. The gas valve port holes are added to the manifold, which is then bent into shape and fitted with threaded connectors. The gas valves are assembled onto the manifold, followed by a regulatory gas tightness test. The gas manifold is assembled onto an LP regulator sub-assembly. The completed gas train assembly undergoes fire testing in accordance with CSA regulatory requirements. Burner Production The raw material (perforated tube steel) is purchased in China, where the tubes are cut to size (approximately 18 inches). One end of the tubes is pressed and sealed. The opposite end is pressed and sealed to create a venturi funnel. A fuel mixer screw is added to this end. The venturi funnel end has a breather hole punched into it and then welded in spider mesh. A cap is welded onto this open end to finalize assembly of the burner. The burner is shipped to the Indonesian / Malaysian factory, where it will be installed into the firebox. The remaining components, such as the including the control panel, cart frame, side shelf, door, exterior cement decorative stones, and cooking area, are manufactured in China and subsequently shipped to Indonesia or Malaysia. At the Indonesian or Malaysian facility, the completed firebox sub-assembly undergoes fire testing in accordance with CSA regulatory requirements before being sent to the pack-out line. The control panel, knobs, and gas train assembly are then installed onto the firebox. The gas train assembly is mounted onto the grill and tested for gas tightness, proper ignition, and combustion. Once all regulatory testing requirements are met, the remaining components are attached using screws, bolts, and nuts to complete the final product. Workers then install labels and clean the product surfaces. Finally, the finished products are packaged to be shipped to the United States for retail sale. 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 non-Indonesia/Malaysia originating materials or components undergo processing in Indonesia/Malaysia which results in a substantial transformation, such that these materials or components lose their individual identities and become an integral part of a new article, possessing a new name, character, and use. Accordingly, from the details submitted, we agree that the country of origin for the propane gas island grills will be Indonesia/Malaysia. 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