OT:RR:NC:N4: 410
Angel Roman Campos
Muncy, Geissler, Olds & Lowe PC
125 S. Royal Street
Alexandria, VA 22314
RE: The country of origin of electric heaters
Dear Ms. Campos:
In your letter dated January 22, 2026, on behalf of your client, Jiangmen Lingfeng Electric Appliances
Manufacturing Co., Ltd., you requested a country of origin ruling on four models of electric heaters for
purposes of marking and applying current trade remedies.
The merchandise under consideration is referred to as “Plastic Heater”, “Metal Heater”, “Stove Heater”, and
“Salamander Heater” (the “heaters”).
You indicate in the ruling letter and subsquent e-mail correspondances that the four electric heater models are
designed for use in household, commercial or industrial environments to provide directed thermal output. All
products incorporate a heating element, an electric motor, a fan to distribute heated air, structural housing
(either plastic or metal), and electrical hardware such as wiring, switches, and connectors. Additionally, the
Stove Heater model contains a printed circuit board (PCB).
You state that both the heating element and the motor are entirely manufactured in Thailand. You also state
that the PCB in the Stove Heater model, the temperature controller for Plastic Heater (SHAG-G33F) model
and the fan blades for Salamander Heater (SHAG-K02F) and Metal Heater (SHAG-G11F) models, are
manufactured in Thailand. The heating elements are constructed using calibrated resistance wire and
integrated thermal control mechanisms. The motors are assembled from core precision parts and are designed
specifically to drive the air circulation required for the heater’s performance. These components are shipped
from Thailand to China as complete subassemblies. The balance of components referenced above will be
made in China.
These heating elements, motors, PCBs, temperature controllers and fan blades are shipped to China, where
they are mechanically installed into each unit with the Chinese-made components without any alteration or
reprocessing to make the finished heaters. You state that the Chinese operations are limited to mechanical
installation of the Thai-origin heating element and motor, wiring of the internal circuitry, mounting of the fan
and structural housing, and final packaging for export. No technical modification or reprocessing of the
Thai-origin components takes place the final assembly in China. You emphasize that these Thai-origin
components, such as heating elements, motors, PCB and temperature controllers, are simply installed using
fasteners and electrical connections during the final assembly in China.
You also explain that across all four heater models, the Thai-manufactured motor and heating element
together constitute the essential, defining components of the product. The motor powers the fan to generate
airflow, while the heating element performs the primary function of heat generation.
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).
Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless
excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous
place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a
manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin
of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be
able to know by an inspection of the marking on the imported goods the country of which the goods is the
product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may,
by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should
influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940).
Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the
country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP
Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or
growth of any article of foreign origin entering the United States. Further work or material added to an article
in another country must effect a substantial transformation in order to render such other country the “country
of origin” within the meaning of the marking laws and regulations.
In regard to the country of origin of the electric heaters, the Thai-origin heating element and the motor/fan are
key components of the electric heaters, which together generate and propel heat, thereby delivering the
essential functionality of the product. The subject merchandise would not function for its intended use
without these key elements. Further, the Thai-origin subassemblies represent the highest-value, most
technically complex, and functionally significant inputs into the final products while the assembly operations
in China are considered simple in nature. Based on the totality of facts, it is our view that the country of
origin for the electric heaters will be Thailand for purposes of marking and applying current trade remedies.
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 Michael Chen at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division