OT:RR:NC:N4:415
Cindi Kavanaugh
Mohawk Global Trade Advisors
4455 Genesee Street
Buffalo, NY 14225
RE: The country of origin of an oven latch assembly from China.
Dear Ms. Kavanaugh:
In your letter dated May 23, 2025, you requested a country of origin ruling on an oven latch assembly on
behalf of your client, HTI Technology & Industries, Inc.
The product under consideration is used to lock the oven door when the self-clean oven function is in
operation. It also serves as a structural component to enhance the stability of the oven’s framework. Your
submission indicates it will come in two configurations.
In the first scenario, the following components are produced in Cambodia: front bracket, location pin, hook,
middle bracket cover plate, middle bracket, connecting rod, and back customer mounting bracket. The power
drive assembly is sourced in China and the screw is from either Cambodia, India, or Taiwan.
In the second scenario, the following components are produced in Cambodia: front bracket, location pin,
hook, middle bracket cover plate, middle bracket, and back customer mounting bracket. The connecting rod
and power drive assembly are sourced in China and the screw is from either Cambodia, India, or Taiwan.
In both versions, the latch assembly undergoes the following manufacturing process in Cambodia:
1. Swage location pin into front bracket.
2. Install power drive assembly onto back customer mounting bracket and fasten with screw.
3. Clinch front, middle, and back customer mounting bracket into one piece.
4. Install hook, connecting rod, and then swage middle bracket cover plate.
5. Perform end of line tests.
6. Laser etch the date code.
7. Package and palletize.
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).
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.
This office is of the opinion that the power drive assembly holds the basic nature of the finished oven latch
assembly. Further, we find that the manufacturing steps performed in Cambodia would be considered simple
assembly and that it does not become a new article having a new name, character, or use. The origin of the
finished component will remain the same as the origin of the power drive assembly as a substantial
transformation does not occur in Cambodia. Accordingly, the country of origin for this oven latch assembly
will be China.
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 CBP Regulations (19 CFR 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 Kristopher Burton at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division