RE: The country of origin of an iron decorative windmill

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 N364778 October 1, 2026 OT:RR:NC:N5:121 CATEGORY: Origin Gina Zhou Twinkle Tide Smart Home Co., Ltd Factory 1A, Plot B3-B4, Tan Hoi 1 Industrial Cluster, Hoi An Hamlet, Tan Hoi Commune Tay Ninh Vietnam RE: The country of origin of an iron decorative windmill Dear Ms. Zhou: In your letter dated September 1, 2026, you requested a country of origin ruling on an iron decorative windmill. Photographs and descriptions of the merchandise and manufacturing process were included in your inquiry. The article under consideration is described as a RS 5ft Duck and Bucket Windmill, SKU# 6104568. It is a freestanding decorative iron windmill intended for use on the porch or in the garden. It features spinning windmill blades and a large metal duck pumping water into a small bucket. A small metal duck and three tufts of grass complete the scene. The windmill measures 31.89 inches x 18.11 inches x 59.45inches, and weighs 14.7 lb. You describe a production process in which several components including the decorative large duck, water pump, hand lever, small bucket, and small duck are stamped out of iron in China. Those components are shipped to Vietnam where they are incorporated with the remaining components that are made in Vietnam including the windmill frame and windmill blades. In Vietnam, the pieces are welded together, polished, powder coated, spray painted, hand painted and then assembled into the finished article. It is then packed for shipping. 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). Based on the provided documentation, some of the decorative components would be made in China and then assembled together with the remaining components made in Vietnam. The Vietnamese components include the structural frame and the distinctive windmill blades. As the parts from China are assembled and afterwards emerge with a new name, character, and use that is different from what they possessed prior to processing, thus completing a substantial transformation, the country of origin in this scenario would be Vietnam. 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 Jennifer Jameson at jennifer.d.jameson@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division