The country of origin of a Winder machine

N359816 April 8, 2026 OT:RR:NC:N1:118 CATEGORY: Origin Minna Talasaho Valmet Technologies Oy Rautpohjankatu 3, PO BOX 587 Jyväskylä 40700 Finland RE: The country of origin of a Winder machine Dear Ms. Talasaho: In your letter dated March 18, 2026, you requested a country of origin ruling. Pictures of the merchandise in different stages of manufacture were included with you submission, along with manufacturing flow charts The item under consideration is a Winder machine. It is a key component in board and paper production lines and is used in the final stage of the manufacturing process. The machine’s primary function is to rewind the large parent rolls of paper or board (which are produced on the main paper machine) into smaller, more manageable rolls according to specific width and diameter requirements. The machine incorporates four main subassemblies: 1) a slitting section manufactured in China, 2) winding drums manufactured in China, 3) a core feeding section manufactured in India, and 4) a wind-up section manufactured in Finland. The wind-up section includes the following components: frame, enclosures, core locks, rider roll equipment, roll ejector, cut-off device, lowering device, nip guard, and tail threading devices. You have stated that the Chinese-origin slitting section and winding drums, and the Indian-origin core feeding section will be shipped to Finland for assembly and testing with the wind-up section. The Winder machine will then be partially disassembled for transport and shipment to the United States. 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). Regarding the finished Winder machine, it is our view that the manufacturing and assembly operations performed in Finland constitute a substantial transformation of the raw materials and foreign subassemblies. The imported subassemblies used to manufacture the Winder machine do not impart the identity or character of a finished Winder machine and have no functionality without the wind-up section, which is manufactured in Finland. It is therefore the opinion of our office that the country of origin of the Winder machine is Finland. 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 Anthony Grossi at anthony.e.grossi@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division