OT:RR:NC:N4:410
Steven Cotto
Baker McKenzie
815 Connecticut Avenue NW
Washington, DC 20006
RE: The country of origin of Weber Slate 28” gas griddle 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 28”, which is a gas griddle designed for domestic
use.
In your request, you illustrate that the Slate 28” griddles would be assembled in Thailand with components
sourced from China and produced in Thailand. The components sourced from China are burner tubes, knobs,
and gas trains. The factories in Thailand will fabricate the balance of the components or sub-assemblies
including the cookbox, griddle, and lid, which are key sub-assemblies, 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, stamping, and welding.
Specifically, the manufacturing process in Thailand encompasses the following seven major steps:
Assemble the hardware pack
The Thai Factory assembles the hardware bag for end-user installation of the product (e.g., screws, washers).
Assemble the accessory package
The Thai Factory assembles the accessory package, which includes the catch pan, casters, knobs, tool hooks,
and other accessories.
Stamp, paint, and assemble the mid panel
The Thai Factory stamps the mid panel from sheet metal and paints the formed panel, and then assembles
bumpers for the cart door onto the panel.
Stamp, weld, and assemble the lid
The Thai Factory stamps the lid, paints the lid, welds the lid top hinge onto the lid, and attaches the logo
badge and warning label to the lid.
Assemble the valve/manifold
The Thai Factory assembles the manifold sub-assembly by fitting the gas line to the manifold fixture,
installing the regulator, performing leakage tests on low and high pressure, recording the results of such tests
in a tracing list, and labeling the sub-assembly accordingly.
Stamp, paint, weld, and assemble the cookbox
The Thai Factory stamps the front, rear, and bottom cookbox panels from sheet metal and paints the shaped
forms and assembles the panels, together with the heat shield, bumper, end caps, burner sub-assembly, grease
chute, gas train, control panel, and panels.
Final assembly for shipment
Lastly, the Thai Factory packages the cookbox, griddle sub-assembly, and other sub-assemblies into a single
cardboard container for shipping.
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 cookbox, griddle,
and lid 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 28”griddles is 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