The country of origin of flatware sets.

N354982 November 5, 2025 OT:RR:NC:N4:415 CATEGORY: Origin Sally Zhou Hans-Mill Corporation 5406 West 1st Street Jacksonville, FL 32254 RE: The country of origin of flatware sets. Dear Ms. Zhou: In your letter dated October 17, 2025, you requested a country of origin ruling on assorted flatware sets. The products under consideration are various flatware sets that will contain knives, forks, and spoons either including a single type of utensil, such as a set of forks, or in combinations of these items. These sets will range from three pieces up to 48 pieces. These utensils will all be made wholly from cold rolled stainless steel. Your submission indicates that there will be two production scenarios. In the first scenario, the stainless steel blanks are manufactured in China from Chinese origin coiled steel. The remaining processing steps including rolling, punching, cutting, forming, grinding, polishing, sharpening, cleaning, inspection, and packing will be performed in Cambodia, Vietnam, or another South Asian country. In the second scenario, the stainless steel blanks are manufactured in China from Chinese origin coiled steel. The proceeding rolling step will also be completed in China. The remaining processing steps including punching, cutting, forming, grinding, polishing, sharpening, cleaning, inspection, and packing will be performed in Cambodia, Vietnam, or another South Asian country. In your submission, you state that these Chinese blanks could be made into knives, forks, or spoons. Further, they have no specific name, feature, or function and at this point in the manufacturing process they are referred to simply as stainless steel blanks. From the provided images, we agree that the Chinese blanks do not exhibit the final shape and form of the finished utensils. 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 reviewed the submitted production process for each utensil, and we hold the opinion that the blanks are substantially transformed to become new articles having a new name, character, or use after being further processed in Cambodia, Vietnam, or another South Asian country. Accordingly, the country of origin for these flatware sets will be the country where the nondescript blanks are worked to the point where they would hold the final form of the finished knife, fork, or spoon. If these sets contain articles from multiple countries, and are classified under subheading 8215.20, then the country of origin would be determined by the utensil in the set subject to the highest rate of duty. 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 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 CBP Regulations (19 CFR 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 Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division