The country of origin of salt and pepper mills.

N362168 July 6, 2026 OT:RR:NC:N4:415 CATEGORY: Origin Sheila Yang Yienn Lih Enterprises Co., Ltd. 25, Hsin Ye Road, An Ping Industrial Zone Tainan Taiwan RE: The country of origin of salt and pepper mills. Dear Ms. Yang: In your letter dated June 8, 2026, you requested a country of origin ruling. Images were provided in lieu of samples. The products under consideration are a salt and pepper mill both with wooden bodies. The pepper mill features components sourced from China and Taiwan, with the carbon steel inner and outer grinder being produced in China. Similarly, the salt mill consists of components sourced from China and Taiwan, with the ceramic inner and outer grinder also being Chinese in origin. The components of both the salt and pepper mill will be assembled in Taiwan to create the finished items. 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). In order to determine whether a substantial transformation occurs when components are assembled into completed products, all factors such as the components used to create the product and manufacturing processes that these components undergo are considered in order to determine whether a product with a new name, character, and use has been produced. No one factor is decisive, and assembly/manufacturing operations that are minimal will generally not result in a substantial transformation. We note these mills are similar to the ones ruled upon in N360156, dated April 17, 2026, and we maintain the opinion that the carbon steel and ceramic grinders have a predetermined end use, have the basic nature of the finished mills, and that they are not substantially transformed to become new articles having a new name, character, or use after the simple assembly performed in Taiwan. Accordingly, the country of origin for these salt and pepper mills will be China. 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 CBP Regulations (19 CFR 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, contact National Import Specialist Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division