The country of origin of a garden cart

N363279 July 22, 2026 OT:RR:NC:N2:201 CATEGORY: Origin Ms. Gillian Wilson AN Deringer 173 West Service Road Champlain, NY 12919 RE: The country of origin of a garden cart Dear Ms. Wilson: In your letter dated July 13, 2026, you requested a country of origin ruling on a garden cart on behalf of your client, Meridian International Co., Ltd. USA, located in Centennial, CO. The article under consideration is a garden cart (Part number 1002750758), which is a utility cart used to transport heavy items. It consists of a high-density polyethylene (HDPE) plastic base, polypropylene (PP) plastic wheels, and a steel handle, stator, and wheel frame. 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). You state that the raw HDPE and PP are sourced from Cambodia and made into the base and wheels in Cambodia. The completed base and wheels are then shipped to China, where they are assembled together with the Chinese steel handle, stator, and wheel frame. The metal handle is attached to the plastic base with screws, and the wheels are attached to the bottom of the base to create the finished garden cart. The finished product is packed into a carton for shipping. We note that the requester subsequently advised this office the manufacturing operations described herein have not yet commenced and that this is a prospective ruling request. Accordingly, production videos could not be provided because no manufacturing has yet occurred. Therefore, our country of origin determination is based on the manufacturing process as described by the requester and is subject to the factual assumptions set forth in this ruling. In ruling N338794, dated April 5, 2024, we reviewed a similar scenario and determined that the assembly process in China was sufficiently complex to render a substantial transformation. We stated in that ruling that the character of the cart is its base and wheels, and because these components were sourced from the same country, we determined the country of origin for the garden cart to be Thailand. In the present case, the base and wheels are both sourced from Cambodia. As a result, the country of origin for the garden cart shall be Cambodia. 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 Matthew Sullivan at matthew.sullivan@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division