OT:RR:NC:N4:415
James K. Horgan
deKieffer & Horgan
1015 Fifteenth Street Northwest
Washington, DC 20005
RE: The country of origin of a razor handle from China.
Dear Mr. Horgan:
In your letter dated May 27, 2025, you requested a country of origin ruling on a shaving razor handle on
behalf of your client, Mammoth Brands, Inc. FKA Harry’s, Inc.
The product under consideration is described as a reusable razor handle that is primarily made from metal.
This handle will be assembled in Thailand from six principal components: a metal body, a handle grip panel,
a connector housing, a connector plunger, a connector ejector, and a connector/handle button. The metal
body will be sourced in China with the remaining components being molded in Thailand.
Your submission states this handle will undergo the following processing:
The handle grip panel is pressed into the metal body, held in place with an interference fit between
plastic alignment bosses on the grip panel and ribbed holes on the metal body. Following this, the
button is snapped into the corresponding opening on the upper back portion of the metal body.
Separately, the connector sub-assembly is assembled by first placing the plunger into the opening on
the back of the housing. The spring is then inserted into the housing, placed over the stem on the
back of the plunger. The ejector is lastly snapped into the housing, holding the prior components in
place. Once assembled, the connector sub-assembly can then be snapped into the opening at the top
of the metal body, completing the handle assembly.
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 metal body holds the basic nature of the finished handle. Further, we
find that the manufacturing steps performed in Thailand 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 handle will
remain the same as the origin of the metal body as a substantial transformation does not occur in Thailand.
Accordingly, the country of origin for this reusable shaving razor handle 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