The country of origin of Weber liquid propane and natural gas grills from Thailand

N361090May 21, 2026OT:RR:NC:N4:410 CATEGORY: OriginSteven CottoBaker McKenzie LLP815 Connecticut Avenue NWWashington, DC 20006RE: The country of origin of Weber liquid propane and natural gas grills from ThailandDear Mr. Cotto:In your letter dated April 28, 2026 , made on behalf of your client Weber-Stephen Products LLC, yourequested a country of origin ruling for the purposes of China Section 301 trade remedies application.The merchandise under consideration is four models of Weber grills, which is liquid propane and natural gasversions of the (i) the Spirit E-210 grill, (ii) the Spirit E-310 grill, (iii) Spirit E-325 grill, and (iii) the SpiritEP-325 grill (the “grills”).In your request, you illustrate that the grills would be assembled in Thailand with components sourced fromChina and produced in Thailand. The components sourced from China are the table, front panels and doors.The factories in Thailand will fabricate the balance of the components or sub-assemblies including thecookbox, lid and grates, which are key sub-assemblies, and combine these components or sub-assemblieswith the China-origin components to make the finished products. The manufacturing process in Thailandincludes the operations of metal forming, bending, stamping, and welding.Specifically, the manufacturing process in Thailand encompasses the following seven major steps:Stamp, paint, and assemble the control panel assemblyThe Thai Factory manufactures the control panel by stamping sheet metal (which includes cutting, blanking,piercing, bending) until the desire shape is achieved. The Thai Factory then silk screens the panel, assemblesthe endcaps to each side of the panel, and cleans the sub-assembly.Stamp grease tray and heat shield; pack alongside table panelThe Thai Factory then manufactures the grease tray by stamping sheet metal and enameling the shaped formand manufactures the heat shield by stamping sheet metal into the desired shape. The Thai Factory packagesthese components alongside a table panel stamped in China. Assemble the hardware kitThe Thai Factory assembles the hardware kits for use by end-customers in installing the grill, which involvespackaging various Chinese-origin tools (e.g., wrenches) and associated hardware (e.g., screws, washers).Stamp, enamel, paint, and assemble the lidThe Thai Factory manufactures the lid by stamping, enameling, and painting sheet metal into the desiredform, and then assembling end caps, a thermometer, and a handle to the lid.Assemble the manifold/valveThe Thai Factory assembles the manifold/valve (controlling the distribution of gas to burners on the cookingsurface) from Chinese-origin brackets, nuts, corrugated tube, and gas tub. The Thai Factory then performsleakage tests in low pressure and high pressure, recording the results of such tests in a tracing list and bylabeling the sub-assembly accordingly.Die cast, paint, and stamp the cookboxThe Thai Factory produces the cookbox sub-assembly by die casting aluminum alloy and assemblingbrackets, burners, and gas rails to the cookbox. The Thai Factory then conducts a flame test to confirmfunctionality.PackageThe Thai Factory packages the Thai-made sub-assemblies alongside China-made sub-assemblies (e.g., thedoor and panels) in preparation for export to the United States.When determining the country of origin for purposes of applying current trade remedies under Section 301and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters RulingLetter H301619, dated November 6, 2018. The test for determining whether a substantial transformation willoccur is whether an article emerges from a process with a new name, character, or use different from thatpossessed 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).This office reviewed the provided assembly process descriptions and is of the opinion that factories inThailand produce a significant a number of components, including key components, e.g., the cookbox, lid,grates, from the material of sheet steel; the non-Thai origin components undergo enough of a change toafterwards emerge with a new name, character, and use that is different from what they possessed prior toprocessing, thus completing a substantial transformation. Therefore, from the details submitted, we agree thatthe country of origin for the grills at issue would be Thailand for the purposes of applying the current traderemedies, China Section 301 remedies do not apply.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Michael Chen at michael.w.chen@cbp.dhs.gov. Sincerely, (for)James P. ForkanDirectorNational Commodity Specialist Division