The country of origin of crystal lamps

N357195 January 13, 2026 OT:RR:NC:N4:410 CATEGORY: Origin Marina Mekheil Schulz Trade Law PLLC 8333 Douglas Avenue, Suite 975 Dallas, TX 75225 RE: The country of origin of crystal lamps Dear Ms. Mekheil: In your letter dated December 19, 2025, on behalf of Visual Comfort of America LLC, you requested a country of origin ruling on crystal lighting fixtures for purposes of applying current trade remedies. The merchandise at issue is thirteen SKUs or Part Numbers of LED lighting fixtures grouped in three series: Pendant lamps (Group 1) – Each consists of a canopy, suspension rod, light source, and lamp cover. The lamp covers are in a globe or cone shape. This group of lights covers the following SKUs or Part Numbers: WF3005XX: 5’’ Rechargeable Accent Lamp. WF3100XX: 7’’ Rechargeable Accent Lamp. WF5100XX: 5’’ Mini Pendant. Pendant lamps (Group 2) – This group of lamps is similar to the above Pendant lamps in Group 1 except for the shapes of the lamp covers. There are two diamond-shaped lamp shades back-to-back secured by a metal ring attached to the end of the suspension rod. This group of lights covers the following SKUs or Part Numbers: WF5006XX: Pendant featuring two Karo Cut Crystals. WF5007XX: Pendant featuring two Olive Cut Crystals. WF5008XX: Pendant featuring one Karo Crystal and one Olive Cut Crystal. Floor lamps, table lamps, and wall lamps (Group 3) – These floor lamps and the table lamps are similar in construction except for the length of the midsection/pole or arm. Each consists of a base, midsection (metal rod), light head (light source) and lamp shade. The wall lamps consist of an arm(s) extended from a back plate, stem(s), light source and lamp shade(s). This group of lights covers the following SKUs or Part Numbers: WF1000XX: One-Light Floor Lamp. WF2000XX, WF2002XX: One-Light Wall Lamps of different sizes. WF2003XX: Two-Light Wall Lamp. WF3000XX, WF3001XX: Table Lamps of different sizes. You refer the lamp shades or lamp covers as “crystal lampshades” and state that the crystal lampshades are designed and manufactured in Ireland (of Ireland origin), and the balance of components are of China origin. In the Philippines where the final assembly will take place, the Ireland-originating crystal lampshades and components from China, e.g., the bases, midsection, back plates, light sources (PCBA populated with LEDs), canopies, and miscellaneous parts or materials (nuts, brackets, gaskets, screws, etc.) are assembled to make the finished lighting fixtures. You also note that the assembly process in the Philippines is not complex, which only involves three to nine simple steps and three to fourteen components being affixed depending on the SKU. The only equipment required is gloves and a screwdriver. The assembly in the Philippines does not require any complex processing, such as soldering, fusing, or machining. In addition, you note that value of Ireland-originating lampshades are more than the China-originating components in general. The selling prices with the crystal lamp shades are 190 to 220 percent to those lamps sold without the crystal lamp shades depending on the SKU numbers. Further, you present that the Waterford crystal is the single most valuable component in the light, it defines how the product is marketed and perceived, and it’s what makes the lamp a luxury item rather than just a commodity. Ultimate consumers of the crystal lamps will purchase them as decorative and luxury products rather than for their functional lighting purpose. The lamps are viewed as statement pieces that represent quality, design excellence, and prestige as they are associated with the Waterford brand. For the ultimate purchaser, owning the lamp is about association with the Waterford brand’s reputation and the status that comes with it, rather than the need to illuminate a space. Accordingly, you suggest that the Ireland-originating lampshades impart the essential character of the lamps, thus, the country of origin of these lamps at issues will be Ireland for the purposes of applying the current trade remedies. We agree. 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). It is of our view that crystal lamp shades impart the character of the lights under consideration. The crystal lamp shades radically alter the appearance of the lights, confer the lights a distinctive, elegantly decorated appearance to the otherwise largely utilitarian character of the lights, give their names for marketability appeal, and add substantial value to the lights. The manufacturing of the crystal lamp shades processing is complex, time-consuming, which is intricate. Thus, we agree that the country of origin for the purposes of applying current trade remedies is Ireland. 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