The country of origin of electric heaters

N357855 February 10, 2026 OT:RR:NC:N4: 410 CATEGORY: Origin Angel Roman Campos Muncy, Geissler, Olds & Lowe PC 125 S. Royal Street Alexandria, VA 22314 RE: The country of origin of electric heaters Dear Ms. Campos: In your letter dated January 15, 2026, on behalf of your client, Jiangmen Lingfeng Electric Appliances Manufacturing Co., Ltd., you requested a country of origin ruling on four models of electric heaters for purposes of marking and applying current trade remedies. The merchandise under consideration is referred to as “Plastic Heater”, “Metal Heater”, “Stove Heater”, and “Salamander Heater” (the “heaters”). Each of the four heater models is designed for use in household, commercial or industrial environments to provide directed thermal output. All products incorporate a heating element, an electric motor, a fan to distribute heated air, structural housing (either plastic or metal), and electrical hardware such as wiring, switches, and connectors. Additionally, the Stove Heater model contains a printed circuit board (PCB). You state that the heating elements and PCBs are manufactured in Thailand using calibrated resistance wire and integrated thermal control mechanisms. The balance of components referenced above will be made in China. These heating elements and PBCs are shipped as prefabricated components to China, where they are mechanically installed into each unit with the Chinese-made components without any alteration or reprocessing. The Chinese operations include final mechanical assembly, electrical wiring, mounting of the fan and motor, installation of the housing, and packaging of the completed unit for export. You further state that these heating elements and PCBs are simply installed using fasteners and electrical connections during the final assembly in China. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. In regard to the country of origin of the electric heaters, all components except for the heating element and PBC are made in China. We note that the motor assembly, fan, and PCB are made in China and that these components account for the majority of the value of the final product. The Thai-origin heating element and PBC enhances the Chinese-made components, including the fan that distributes the heated air. Without the Chinese-origin motor and fan to actually distribute the heat from the heating element, the subject merchandise would not function for its intended use. While the heating element plays an important role in the intended use of the heaters, this component alone does not impart the functionality of the heaters. In examining the totality of the facts, we note that the majority of the components, including key components such as the fan, and motor assembly - which are essential to the proper functioning of the heater - are of Chinese origin, and the final assembly also occurs in China, therefore, it is our view that the country of origin for the electric heaters will be China for purposes of marking and applying current trade remedies. 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, Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division