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 N365093 October 5, 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 September 16, 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 it. Three metal chains are connected to a hook (referred to as the “S-hook and iron chains”) at the top of the dome for hanging. 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 are the S-hook, iron chains, and nylon strings. The balance of components, including the top pieces, flowers, rooster bodies, clappers, and windcatchers, are produced in Vietnam. The assembly process in Vietnam includes making the metal components from raw metal sheets and tubes, and combining them with the Chinese-origin S-hook, iron chains and stings to fabricate the finished windchimes. This manufacturing process involves metal stamping, cutting, 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 90% of the total cost of 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 vast majority of the components, including the metal components made 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. Consequently, the manufacturing process in Vietnam is considered sufficiently “complex and meaningful” as to result in a substantial transformation. Accordingly, we believe that the country of origin for the windchimes will be Vietnam 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