RE: The tariff classification, country of origin, and marking of a beaded valance

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 N365556 October 16, 2026 CLA-2-44:OT:RR:NC:N5:130 CATEGORY: Classification; Country of Origin; Marking TARIFF NO.: 4421.99.9880 Antti Aimo Juhani Kotajärvi 1000Beads Kirkkokatu 48 A 19 2 Oulu, 90120 Finland RE: The tariff classification, country of origin, and marking of a beaded valance Dear Antti Aimo Juhani Kotajärvi: In your letter, dated September 30, 2026, you requested a binding classification, country of origin, and marking ruling on a beaded valance. Information and photos were submitted for our review. The product under consideration is item BV26-01, a beaded valance. The item consists of an aluminum profile that is drilled and strung with several strands of wooden beads. The beads measure 12mm in diameter and are strung in a specific color order to form a picture of a branch with leaves and apples. The strands are specific lengths so that the bottom edge of the valance follows the shape of the apples and leaves. The valance is designed to be used in a doorway, much like a beaded curtain, but does not block the full doorway. The valance styles measure up to one meter wide and are up to 600mm in length. The applicable subheading for item BV26—01 beaded valance will be 4421.99.9880, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other articles of wood: Other: Other: Other: Other: Other. The general rate of duty will be 3.3 percent ad valorem. In your letter, you outline a scenario wherein aluminum profiles and bulk, colored wooden beads are imported into Finland from China, and nylon cord is imported into Finland from the UK. In Finland, the aluminum profiles are drilled and deburred, and various colors of beads are strung in order and threaded into the aluminum profiles. The finished profile is capped on both ends, and the valance is packaged. Section 134.1(b) of the Customs and Border Protection Regulations (19 CFR 134.1(b)) provides that the "[c]ountry of origin" means the country of manufacture, production or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the "country of origin" within the meaning of Part 134, Customs and Border Protection Regulations (19 CFR Part 134). Substantial transformation requires that "[t]here must be a transformation; a new and different article must emerge, ‘having distinctive name, character, or use.’" Anheuser-Busch Brewing Association v. United States, 207 U.S. 556, 28 S. Ct 204 (1908). We must therefore determine where a substantial transformation of materials occurs in order to determine country of origin. U.S. Customs and Border Protection has held that bead stringing constitutes simple assembly. Additionally, drilling of a profile does not constitute substantial transformation. Therefore, the profile and beads are substantially transformed when they are made in China. China is the country of origin. The product can be marked “Made in China” or “Product of China” as appropriate. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/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 Laurel Duvall at laurel.duvall@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division