RE: The country of origin of a metal chicken windchime

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364414 September 15, 2026 OT:RR:NC:N4:410 CATEGORY: Origin Gina Zhou Twinkle Tide Smart Home Co. Ltd Lot No. B3-B4, Tan Hoi 1 Industrial Park, Hoi An Hamlet Tan Hoi Commune, Tan Chau District, Tay Ninh Province Vietnam RE: The country of origin of a metal chicken windchime Dear Ms. Zhou: In your letter dated August 20, 2026, you requested a country of origin ruling on a windchime for purposes of current trade remedies. The product under consideration is a windchime identified as the RS 31.5in metal chicken windchime, which measures approximately 31.5 inches in height and 8 inches in diameter. Each windchime consists of a dome-shaped metal top piece with metal tubes, flowers, roosters, a clapper, and a flower windcatcher suspended beneath. Three metal chains are connected to a hook at the top of the dome for hanging. In your ruling request submission and subsequent email correspondence, you state that the windchimes are assembled in Vietnam using components sourced from both China and Vietnam. The components sourced from China include the top pieces, flowers, rooster bodies, clappers, and windcatchers. The components of Vietnamese origin are the rooster wings and tubes. The factory combines these Vietnamese-origin components with the Chinese-origin parts to create the finished windchimes. The assembly process in Vietnam begins by welding the imported components. Specifically, the factory in Vietnam welds the Chinese-origin rooster bodies and the Vietnamese-origin wings together to form complete roosters. These roosters are then combined with the other imported components and the Vietnamese-made metal tubes (chimes) to assemble the finished windchime. This manufacturing process includes spot welding, polishing, powder coating, paint spraying, and hand-painting (using coating and paint of Vietnamese origin). Finally, the finished products undergo testing and inspection before being packaged for export. The Bill of Materials (BOM) demonstrates that the manufacturing operations in Vietnam contribute approximately 31% of the total cost of production and final value of the windchimes. 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). This office reviewed the manufacturing process and notes that all components except for the chimes and rooster wings are imported from China. The Chinese-originating parts or components are designed to be a rooster windchime. The welding and other assembly operations in Vietnam simply put those pre-determined parts together. Even if the process requires welding and manual dexterity like hand-painting, it does not create a "new and distinct article of commerce" because the character and use were already fixed. Consequently, the manufacturing process is not considered sufficiently “complex and meaningful” as to result in a substantial transformation in Vietnam. Accordingly, we believe that the country of origin for the windchimes will be China for the purposes of 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 P. Forkan Director National Commodity Specialist Division