MAR-2 OT:RR:NC:N4:410
Mr. James K. Kearney
Womble Bond Dickinson (US) LLP
8065 Leesburg Pike. Fourth Floor
Tysons Corner, VA 22182-2738
RE: The country of origin determination of string light sets
Dear Mr. Kearney:
This is in response to your letter dated November 2, 2018, on behalf of your client Everstar Merchandise Co., Ltd. /Tomson Merchandise Co., Ltd., requesting a country of origin determination for string light sets, featuring miniature incandescent bulbs.
Each of the light string sets consists of the following components: Light bulbs and electric wires made in China; (common) Electric wires, a color box, a carton, a plug, an end connector and fuses made in Cambodia.
You illustrated the Cambodian’s assembly operation processing steps as follows:
Use the Chinese’ imported plastic granules to make lamp holders and lamp husks
Connect the incandescent light bulbs to a lamp holder and lamp husk. Making the lamp in a finished lamp assembly machine
Cut the wires to length
Assemble the lamp socket, the plug and the connector
Connect all the components (lamp, lamp husks, wires, copper contacts/terminals) to make the light string
Cut and peel the wire and then clamp it to terminal(s)
Test the light set, tidy up and inspect light sets
Label and final package
Section 134.1(b), Customs Regulations (19 C.F.R. § 134.1(b)), defines "country of origin" as 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”.
The assembly operations performed in Cambodia substantially transforms the Chinese originating components/materials into Cambodian products. The assembly in Cambodia of the individual components to produce the finished string light sets creates a new and different article of commerce with a distinct character and use that is not inherent in the components imported into Cambodia.
Based on the information submitted, we are of the opinion that the processing performed in Cambodia with respect to the string light sets does constitute a substantial transformation of all the imported materials into "products of" Cambodia. Therefore, the "product of" requirement has been satisfied. For tariff purposes, it is of the opinion of this office that the country of origin for the string light sets featuring miniature incandescent bulbs will be Cambodia.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 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, contact National Import Specialist Hope Abada at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division