The country of origin of microwave ovens from Thailand

N357004 January 6, 2026 OT:RR:NC:N4:410 CATEGORY: Origin Nate Bolin K&L Gates LLP 1601 K Street NW Washington, DC 20006 RE: The country of origin of microwave ovens from Thailand Dear Mr. Bolin: In your letter dated December 14, 2025, you requested a country of origin ruling on microwave ovens made on behalf of your client, Thai Toshiba Electric Industries Co., Ltd. (“TTEI”). The products under consideration are described as the “EM720C Microwave Ovens”, TTEI model number EM720C-PM0A00 with customer model numbers EM720C2RD, NS-MW7WH5, and NS-MW7BK5. The EM720C Microwave Ovens are 20-liter and 700-watt electric-power solo function microwave ovens for household use for sale to individual consumers. The EM720C Microwave Ovens are electric countertop cooking devices sold individually in a single, packaged unit. These microwave ovens cook food by generating microwaves through a magnetron, which causes water and other polar molecules in the food to vibrate and produce heat. Except for the minor variations in the color, accessories (or features) and the design of the door panel, all units subject to the ruling request will use the same platform and share the same production process, and all three models of the EM720C Microwave Ovens subject to the ruling request have the same components. The EM720C Microwave Ovens are produced in Thailand through a manufacturing and assembly process comprising three main stages. In the first stage, key components are manufactured in Thailand from various raw materials. Specifically, TTEI manufactures metal parts of the EM720C Microwave Ovens from steel materials. Further, TTEI manufactures the printed circuit board assembly (“PCBA”) of the EM720C Microwave Ovens in Thailand. In the second stage, TTEI manufactures the cavity subassembly, control panel subassembly, lamp subassembly, fan subassembly, and base plate subassembly of the EM720C Microwave Ovens. Finally, in the third stage, TTEI conducts the final assembly in Thailand, followed by testing and packaging of each unit of the EM720C Microwave Ovens. The first stage is production of components in Thailand, which involves two phases: (1) The production of metal parts: The front plate, back plate, U-shaped plate, top plate, base plate, and outer case top plate are made in Thailand from Chinese-produced steel materials by stamping and similar working techniques, and using the powder coating line equipment to conduct powder coating on the outer case. (2) The production of the PCBA: The PCBA of the EM720C Microwave Ovens is manufactured by TTEI in Thailand from Chinese-produced components using surface mount technology (SMT). TTEI uses an axial insertion machine, radial insertion machine, surface mount technology machine, an automated optical inspection machine, and a computer (or a program writing machine), among other machines. The second stage involves the production of the subassemblies for the EM720C Microwave Ovens in Thailand. Following the production of the metal components and PCBA, TTEI manufactures in Thailand the cavity subassembly, control panel subassembly, lamp subassembly, fan subassembly, and base plate subassembly of EM720C Microwave Ovens. The cavity subassembly of the EM720C Microwave Ovens is composed of the front plate, U-shaped plate, back plate, top plate, turntable motor bracket, and wave guide bracket, among other components. The subassembly is produced by bending certain metal components, welding the components together, powder coating the cavity, and assembling the lock switch and splash shield. The control panel subassembly of the EM720C Microwave Ovens is comprised of the control panel, PCBA, and membrane switch. The production process in Thailand specifically includes fixing the membrane on the control panel and assembling the PCBA to the control panel. The lamp subassembly of the EM720C Microwave Oven is comprised of the integrated lamp and lamp bracket. The production process in Thailand specifically includes assembling the lamp to the lamp bracket. The fan subassembly of the EM720C Microwave Ovens is comprised of the fan motor, the plastic fan blade, and the fan bracket. The production process in Thailand specifically includes assembling the fan motor with the fan bracket and the plastic fan blade. The base plate subassembly of the EM720C Microwave Ovens is comprised of the base plate, door lower hinge, rubber feet, high-voltage diode, capacitor holder, and high-voltage capacitor. In the final stage, TTEI will place the Thai-produced metal components and the Thai-produced subassemblies with the remaining components from Thailand and China on the main assembly line to produce the completed EM720C Microwave Ovens. The final production process can generally be divided into three different phases: (1) manufacturing/assembly, (2) inspection and testing, and (3) packaging. 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 Thailand 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 Thailand. Thus, from the details submitted, we agree that the country of origin for these Microwave Ovens, will be Thailand as you proposed. 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