The country of origin of electric heaters

N358925 March 3, 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 February 17, 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 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). The PCB converts AC mains power into low-voltage DC suitable for the dimming circuit. A linear potentiometer is matched with a power switching device. Rotating the potentiometer adjusts the loop resistance, changing the LED lamp’s operating current and enabling stepless brightness adjustment. The Surface Mount Technology (SMT) processing of the PCB is also conducted in Thailand. You state that both the heating element and the motor are entirely manufactured in Thailand. You also state that the printed circuit board in the Stove Heater model is manufactured in Thailand. The heating elements are constructed using calibrated resistance wire and integrated thermal control mechanisms. The motors are assembled from core precision parts and are designed specifically to drive the air circulation required for the heater’s performance. These components are shipped from Thailand to China as complete subassemblies. The balance of components referenced above will be made in China. These heating elements and motors 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 to make the finished heaters. You state that the Chinese operations are limited to mechanical installation of the Thai-origin heating element and motor, wiring of the internal circuitry, mounting of the fan and structural housing, and final packaging for export. No technical modification or reprocessing of the Thai-origin components takes place during the final assembly in China. You emphasize that these heating elements and motors are simply installed using fasteners and electrical connections during the final assembly in China. You also explain that across all four heater models, the Thai-manufactured motor and heating element together constitute the essential, defining components of the product. The motor powers the fan to generate airflow, while the heating element performs the primary function of heat generation. 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). In regard to the country of origin of the electric heaters, the Thai-origin heating element and the motor are key components of the electric heaters, which together generate and propel heat, thereby delivering the essential functionality of the product. The subject merchandise would not function for its intended use without these key elements. Further, the Thai-origin subassemblies (including the PCBs produced through SMT procedures) represent the highest-value, most technically complex, and functionally significant inputs into the final products while the assembly operations in China are considered simple in nature. Based on the totality of facts, it is our view that the country of origin for the electric heaters will be Thailand for purposes of 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, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division