OT:RR:NC:N4:422
Mr. William Yeh
Design International Group, Inc.
755 Epperson Drive
City of Industry, CA 91748
RE: The country of origin of a plastic serving bowl and utensil set
Dear Mr. Yeh:
In your letter dated August 20, 2025, you requested a country of origin ruling on a plastic serving bowl and
utensil set.
The item under consideration is a plastic serving bowl and utensil set, item WIC 666808. The items are all
made of melamine plastic. The round serving bowl, plastic serving fork, and plastic serving spoon will be
packaged and sold together for retail sale. The articles are designed for serving of salads, pasta, and other
prepared foods. The plastic serving bowl measures approximately 11.5 inches in diameter and is 4 inches
high. The plastic serving fork and spoon both measure 11 inches long by 3 inches wide.
Based on the information you provided, the raw materials are sourced from Vietnam.
The production process in Vietnam is divided into four phases including: 1. manufacturing, which includes
preparing the melamine compound into a serving bowl and serving utensils, 2. assembling, polishing and
decal printing, 3. packaging, 4. testing and inspection. In your letter, you state that all processing occurs at
the manufacturer facility in Vietnam.
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).
Based on the facts you have submitted regarding the production of the plastic serving bowl and utensil set,
the country of origin is 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 Dana L. Giammanco at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division