OT:RR:NC:N4:410
Steven Cotto
Baker McKenzie LLP
815 Connecticut Avenue NW
Washington, DC 20006
RE: The country of origin of Weber liquid propane and natural gas grills 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 four models of Weber grills, which is liquid propane and natural gas
versions of the (i) the Spirit E-210 grill, (ii) the Spirit E-310 grill, (iii) Spirit E-325 grill, and (iii) the Spirit
EP-325 grill (the “grills”).
In your request, you illustrate that the grills would be assembled in Thailand with components sourced from
China and produced in Thailand. The components sourced from China are the table, front panels and doors.
The factories in Thailand will fabricate the balance of the components or sub-assemblies including the
cookbox, lid and grates, which are key sub-assemblies, and combine these components or sub-assemblies
with the China-origin components to make the finished products. The manufacturing process in Thailand
includes the operations of metal forming, bending, stamping, and welding.
Specifically, the manufacturing process in Thailand encompasses the following seven major steps:
Stamp, paint, and assemble the control panel assembly
The Thai Factory manufactures the control panel by stamping sheet metal (which includes cutting, blanking,
piercing, bending) until the desire shape is achieved. The Thai Factory then silk screens the panel, assembles
the endcaps to each side of the panel, and cleans the sub-assembly.
Stamp grease tray and heat shield; pack alongside table panel
The Thai Factory then manufactures the grease tray by stamping sheet metal and enameling the shaped form
and manufactures the heat shield by stamping sheet metal into the desired shape. The Thai Factory packages
these components alongside a table panel stamped in China.
Assemble the hardware kit
The Thai Factory assembles the hardware kits for use by end-customers in installing the grill, which involves
packaging various Chinese-origin tools (e.g., wrenches) and associated hardware (e.g., screws, washers).
Stamp, enamel, paint, and assemble the lid
The Thai Factory manufactures the lid by stamping, enameling, and painting sheet metal into the desired
form, and then assembling end caps, a thermometer, and a handle to the lid.
Assemble the manifold/valve
The Thai Factory assembles the manifold/valve (controlling the distribution of gas to burners on the cooking
surface) from Chinese-origin brackets, nuts, corrugated tube, and gas tub. The Thai Factory then performs
leakage tests in low pressure and high pressure, recording the results of such tests in a tracing list and by
labeling the sub-assembly accordingly.
Die cast, paint, and stamp the cookbox
The Thai Factory produces the cookbox sub-assembly by die casting aluminum alloy and assembling
brackets, burners, and gas rails to the cookbox. The Thai Factory then conducts a flame test to confirm
functionality.
Package
The Thai Factory packages the Thai-made sub-assemblies alongside China-made sub-assemblies (e.g., the
door and panels) in preparation for export to the United States.
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 a number of components, including key components, e.g., the cookbox, lid,
grates, from the material of sheet steel; the non-Thai origin components undergo 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 grills at issue 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