OT:RR:NC:N4:410
Nate Bolin
K&L Gates LLP
1601 K Street, N.W.
Washington, DC 20006
RE: The country of origin of electric ranges from Vietnam
Dear Mr. Bolin:
In your letter dated April 2, 2026, you requested a country of origin ruling on behalf of your client, Vietnam
Jinwen Intelligent Electrical Appliance Industry Company Ltd. (“Jinwen”).
The merchandise under consideration is three models of electric ranges, model numbers MCR30S2AST,
MCR30S2ABB, and MCR30S2AWW (the “Electric Ranges”). The Electric Ranges are free-standing electric
(i.e., coil-burner) ranges for household use sold individually in single, packaged units.
The Electric Ranges cook, heat, and bake food by using metal heating coils to convert electrical energy into
heat, which is then radiated throughout the oven cavity. Jinwen manufactures the Electric Ranges in three
colors, i.e., white, black, and stainless steel. Except for the minor variations in color, all units subject to the
ruling request use the same platform and share the same production process.
In your request, you indicate that the Electric Ranges would be assembled in Vietnam from components
sourced from China, Mexico and Vietnam. From the provided documentation, the bulk of the parts to
construct the range will be from China. The Electric Ranges are produced in Vietnam through a
manufacturing and assembly process comprising three main stages. In the first stage, a third-party
manufacturer manufactures key metal components of the Electric Ranges in Vietnam from steel sheets
through metal stamping techniques, followed by powder coating or enameling of certain components. In the
second stage, Jinwen manufactures the key subassemblies of the Electric Ranges, such as the door
subassembly, small cabinet door subassembly, energy regulator subassembly, and foot support subassembly.
Finally, in the third stage, Jinwen conducts the final assembly of the Electric Ranges in Vietnam, followed by
testing and packaging of each unit. We note that many of the parts purchased from outside of Vietnam would
be used to form subassemblies, which would later be assembled into the respective ranges. To complete the
manufacturing of this range, pneumatic screwdrivers would be primarily utilized.
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).
This office reviewed the provided assembly process descriptions and is of the opinion that the
non-Vietnamese origin components underwent enough of a change to afterwards emerge with a new name,
character, and use that is different from what they possessed prior to processing, thus completing a
substantial transformation. Therefore, from the details submitted, we agree that the country of origin for this
electric ranges would be Vietnam for the purposes of applying the 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)
James P. Forkan
Director
National Commodity Specialist Division