RE: The country of origin of the sunflower windchime from Vietnam

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 N364881 September 28, 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 the sunflower windchime from Vietnam Dear Ms. Zhou: In your letter dated September 7, 2026, you requested a country of origin ruling on windchimes for the purposes of current trade remedies. The product under consideration is a windchime that measures approximately 31.5 inches in height and 12 inches in diameter at its widest point. Each windchime consists of a metal utility hook attached to a short link chain through a small “extended round nut,” and a metal full-bloom sunflower topper featuring a disc floret and ray florets (petals). Suspended beneath this crown is a rigid, circular black metal band that serves as the chime support, which is held in place by three small metal chains connected to a central axis rod. Four metal tubes of varying lengths are hung below the ring by nylon braided cords. A striker (a flat, circular black metal disc) is suspended by a braided cord at the heart of the chime array, and a smaller metal sunflower hangs at the very bottom of the windchime to serve as a wind catcher. In your ruling request submission, you state that the windchimes are assembled in Vietnam using components sourced from both China and Vietnam. The components sourced from China include the utility hooks, iron chains, extended round nuts, and nylon braided cords. The balance of components—namely, the sunflowers (the topper and wind catcher), chime supports, iron tubes (chimes), and strikers—are produced in Vietnam. The factory combines these Vietnamese-origin components with the Chinese-origin parts to create the finished windchimes. The assembly process in Vietnam begins by making the metal disc florets and ray florets (petals) from metal sheets through stamping, and O-rings and cross bars through cutting, then welding these metal components to create complete sunflowers and the chime support. These parts are further combined with the Chinese-originating components to fabricate the finished windchimes. Overall, this manufacturing process in Vietnam involves metal cutting, stamping, spot welding, polishing, powder coating, paint spraying, and hand-painting (with Vietnamese-originating coating and paint). 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 contributes approximately 86% of 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 provided assembly process descriptions and is of the opinion that the factories in Vietnam manufacture a majority of the components, including the metal sunflowers and tubes (chimes), from sheet steel and tubes. Furthermore, the non-Vietnamese origin components undergo a sufficient change to emerge with a new name, character, and use different from what they possessed prior to processing, thereby resulting in a substantial transformation. Therefore, the country of origin for the windchimes at issue is Vietnam for the purposes of applying the 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