OT:RR:NC:N4:410
Steven Cotto
Baker McKenzie
815 Connecticut Avenue
Washington, DC 20006
RE: The country of origin of gas griddles from Thailand
Dear Mr. Cotto:
In your letter dated April 28, 2026, made on behalf of your client Weber-Stephen Products LLC, you
requested a country of origin ruling for the purposes of China Section 301 trade remedies application.
The merchandise under consideration is referred to as Slate 17” and 22” griddles, which is two models of gas
griddles. The griddles differ primarily in respect to the number of burners and cooking space - the Slate 17”
features one burner and 272 inches of cooking area and the Slate 22” features two burners and 352 inches of
cooking area.
In your request, you illustrate that the Slate 17” and 22” griddles would be assembled in Thailand with
components sourced from China and produced in Thailand. The components sourced from China are burner
tubes, valves, and legs. The factories in Thailand will fabricate the balance of the components or
sub-assemblies including the lid, cookbox, and griddle, and combine these components or sub-assemblies
with the China-origin components to make the finished products which includes the operations of metal
forming, bending, punching, stamping, and or deep-drawing.
Specifically, the manufacturing process in Thailand encompasses the following five major steps:
Assemble the accessory kit
The Thai factory assembles the accessory kit by packaging the drip pan, tank holder, hardware bag, and lid
handle into the accessory kit package.
Assemble the valve
The Thai factory then assembles the valve sub-assembly by installing the valve onto a gas line, testing the
valve under low and high pressure, and recording the results.
Deep draw, paint, and assemble the lid
The Thai factory deep draws the lid, paints the lid, and attaches the lid top hinge to the lid, and attaches the
logo badge and warning label to the lid.
Deep draw and assemble the cookbox
The Thai factory deep draws and enamels the cookbox from sheet metal and stamps the grease chute and
griddle bracket, and then installs the catch pan rail, cookbox feet, leveling foot sub-assembly, side rail (where
the valve sub-assembly is hosted), and other attachments before ignition testing the cookbox.
Final assembly for shipment
Lastly, the Thai factory packages the lid sub-assembly, cookbox sub-assembly, and accessory kit into
cardboard packaging for shipment.
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).
This office reviewed the provided assembly process descriptions and is of the opinion that factories in
Thailand produce a significant number of components, including key components, i.e., the main lids,
cookbox, and griddle from the material of sheet steel; the non-Thai 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 the Slate 17” and 22” griddles would be Thailand for the purposes of
applying the current trade remedies, China Section 301 remedies do not apply.
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