OT:RR:NC:N1:103
Lancy Jin
Prulde Electric Appliance (Thailand) Co., Ltd.
7/528 Moo 6 Mabyangporn
Pluakdaeng, Rayong 21140
Thailand
RE: The country of origin of a heat gun
Dear Ms. Jin:
In your letter dated January 14, 2026, you requested a country of origin ruling.
The merchandise under consideration is identified as a Kobalt 12.5-amp heat gun, which was also the subject
of New York ruling N328954, dated November 15, 2022. Moving forward, the subject heat gun will be made
using a second manufacturing scenario and imported under SKU 5208257_202601.
In New York ruling N328954, the heat gun was assembled in Thailand with the following components of
Chinese origin: an electric motor, a printed circuit board assembly (PCBA), a fan, an electrical switch, a
power cord, a knob, a back cover, a motor support, a heat insulator, wiring, support rings, and fasteners. In
the new scenario, the heat gun will incorporate a greater number of Thai components, including a heating
element, an electric motor, a PCBA, a fan, a temperature adjustment knob, a power cord, a back cover, and
the outer shells. Electrical switches, terminal blocks, wires, and various fasteners will continue to be sourced
from China. Final assembly will occur in Thailand and begins with the assembly of the heating element and
electric motor.
The heating element is assembled by winding a wire around a steel core fitted with ceramic pipes, inserting
the core into a metal tube insulated with mica sheets, and soldering a safety fuse.
The process continues with assembling the rotor assembly for the electric motor. This involves stamping
laminations out of silicon steel sheets, stacking the laminations onto a shaft, applying a coating of insulating
material, and heat treating the assembly inside a furnace. Afterwards, a worker presses a commutator onto the
shaft and winds a wire around the lamination core.
A stator assembly is produced by pressing a bearing into a housing, gluing a magnetic shoe and a spring to
the housing, and magnetizing the assembly. To complete the motor, a worker presses the rotor assembly into
the stator assembly and secures a rear cover assembly (composed of a metal cover, rubber cover, carbon
brush holder, carbon brush, and spherical bearing).
Final assembly involves attaching the fan to the motor, soldering the wiring from the heating element to the
switch, connecting the motor to the PCBA, mounting the PCBA and motor in the rear shell, securing the
power cord, installing the temperature knob, attaching the front nozzle, and fastening the front shell.
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).
CBP has held that whether an assembly process is sufficiently complex to rise to the level of a substantial
transformation is determined upon consideration of all the operations that occur within that country. We note
that the final assembly steps remain largely the same when compared to the scenario described in New York
ruling N328954. In the new manufacturing scenario, certain key components used during final assembly
(e.g., the heating element, electric motor, PCBA, and fan), which impart the character and use of the heat
gun, will now be manufactured in Thailand. Collectively, these components allow the heat gun to deliver hot
air and fulfill its intended function. Therefore, in view of these facts, and based on the totality of the
circumstances, the country of origin of the subject heat gun will be Thailand.
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 Paul Huang at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division