OT:RR:NC:N5:121
Ken Lai
Great Bay Trading, Inc.
2521 Grant Avenue
San Leandro, CA 94579
RE: The country of origin of steel door hinges
Dear Mr. Lai:
In your letter dated May 8, 2025, you requested a country of origin ruling on steel door hinges.
The merchandise under consideration is described as steel door hinges. They are made of steel with grade of
1008 or stainless steel of grade SUS304 and produced to the ANSI/BHMA A156.1 standard. At the time of
importation, the completed hinges and required number of mounting screws are packed in the same
master-carton. The hinges are packed flat into a small cardboard tray, 25 hinges per tray. There are a total of
100 hinges in one master-carton.
You describe a scenario in which all the components of the hinge - the leaves, pin, and mounting screws are
sourced or manufactured in Vietnam and then exported to China to be plated, powder-coated, or painted into
different finishes; assembled; and packed with the required number of screws into one master carton for
export to the United States.
You state the raw steel is sourced, cold-rolled into flat sheets, cut into strips, die-cut and roll-formed into the
leaves of a hinge in Vietnam. The die and mould are made to specifications to have the desired size, corners,
screw-hole location, screw hole diameters, etc. The worker uses a hydraulic press to push the die into the
mould to punch the steel strip, roll form the steel strip into a hinge leaf with a barrel, and form the screw-hole
countersinks, all in one process at the same time. The hinge leaves, the hinge pin, and the metal screws are
then exported to China where they will be plated, powder-coated, or painted into different finishes (i.e.,
colors) such as a polished yellow gold, bright chrome, brushed nickel, powder-coated matte black, or painted
white. Then the leaves are assembled with a pin and packed with the required number of screws into one
master carton for export to the United States.
When determining the country of origin for purposes of applying current trade remedies under Section 301
and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling
Letter 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). In order to determine whether a
substantial transformation occurs when components are assembled into completed products, all factors such
as the components used to create the product and manufacturing processes that these components undergo are
considered in order to determine whether a product with a new name, character, and use has been produced.
No one factor is decisive, and assembly/manufacturing operations that are minimal will generally not result
in a substantial transformation. It is the opinion of this office that the plating, powder coating, or painting,
and the simple assembly of the Vietnamese components in China do not result in a substantial transformation.
As such, the country of origin for these subject hinges would be Vietnam.
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 Jennifer Jameson at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division