RE: The country of origin of metal wax warmers

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 N365094 October 6, 2026 OT:RR:NC:N4:410 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 Province Vietnam RE: The country of origin of metal wax warmers Dear Ms. Zhou: In your letter dated September 16, 2026, you requested a country of origin ruling determination on a metal lantern wax warmer for purposes of current trade remedies. The product under consideration is a metal wax warmer in the form of a cylindrical lantern. Each wax warmer consists of a finial (iron ring and hanger), a wax melt dish atop, a metal lantern cap, a light bulb, a socket, a protective cage (cage bars and guard ring), a glass cylinder, faux wood accent rings (one circling just under the top cap and the other framing the bottom base), a pedestal base, a power cord, and wax. The submitted literature indicates that all components are produced in Vietnam, except for the lamp sockets, which are imported from China. The assembly process in Vietnam includes making the metal components, the glass cylinders, faux wood accent rings, light bulbs, power cords, and wax, then combining these Vietnam-originating components with the imported lamp sockets to fabricate the finished wax warmers. Overall, this manufacturing process in Vietnam involves metal cutting, stamping, spot welding, polishing, powder coating, plastic injection molding, paint spraying, and hand-painting (with Vietnamese-origin 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 contribute approximately 97% of the total cost of production and final value of the finished products. 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 almost all of the components from raw materials. Furthermore, the components of non-Vietnamese origin—the lamp sockets—undergo a sufficient change to emerge with a new name, character, and a use different from what they possessed prior to processing, thereby resulting in a substantial transformation. Therefore, the country of origin for the wax warmers 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