OT:RR:NC:N4:410
Long Chen
Thai Jiuzhou Electron Co Ltd.88/152 Moo 15
Bangsaotong Sub-District, Bangsaotong 10570
Thailand
RE: The country of origin of three oven lamps
Dear Mr. Chen:
In your letter dated July 13, 2026, you requested a country of origin ruling on three oven lamps for the
purposes of current trade remedies.
The merchandise under consideration is referred to as Item 1 Wall Oven Lamp (191D7209), Item 2 Wall
Oven Lamp (191D7477) and Item 3 Apex Lamp (301D1481). The Bill of Materials and the component
pictures indicate that the Wall Oven Lamps in Item 1 and Item 2 appear to be highly similar in construction
except for the shape of the light head (housing). Each of these oven lamps consists of a glass lens, a metal
housing containing a socket, a light bulb and electrical wires with plug or connector at either end.
Additionally, Item 2 also has a metal clip.
The Apex Lamp (Item 3) consists of a dome-shaped glass lens, metal case (housing), metal pin, light bulb
and a socket with two pins for connection to a power supply.
The procedures for the making of components are illustrated as follows:
Glass Lens
Melting sand and molding the liquid to form a glass lens.
Metal Case, Metal Clip and Metal Pin
Cutting the stainless steel sheet and making the metal case using a progressive stamping mold.
Ceramic Lamp Socket and Plug
Pouring a ceramic powder slurry/sand into the mold and then firing it in a kiln to fuse the
particles together. After firing, the ceramic component is then assembled with the metal
terminals.
Bulb
Forming a coil of metal to make the wire, melting the sand to make a glass tube, and mounting
the metal filament inside a glass bulb. Finally, attaching the connectors to the bulb for
electrical connection.
Harness
Clamping the terminals to the electrical wires to make the harness. The terminals and the
wires are made in China via operations of metal drawing, plastic extrusion, etc.
Connector and Retainer
Melting the plastic pellet and making the plastic parts via plastic injection molding operations.
The factory in Thailand will assemble the Thai-origin components and components imported from China (of
Chinese-origin) to produce the finished lights.
Specifically, you present two different manufacturing process scenarios as follows:
Scenario 1
The assembly process for the lamps in Thailand is summarized as follows:
Item 1 - The metal case, and harness are made in Thailand, and the glass lens, halogen bulb,
ceramic, connector, and retainer are imported from China. In Thailand, the metal case is made
from stainless steel sheet by progressive stamping mold; and the harness is made by clamping
the terminals to the wires from the imported electric wires and terminals.
Item 2 - The metal case and metal clip are made in Thailand, and the glass lens, halogen bulb,
ceramic, connector, and retainer are imported from China. In Thailand, metal case and metal
clip are made from stainless steel sheet by progressive stamping mold; and the harness is made
by clamping the terminals to the wires from the imported electric wires and terminals.
Item 3 - The metal case and metal pin are made in Thailand, and the glass lens, halogen bulb,
and ceramic socket are imported from China.
Scenario 2
The assembly process for the three oven lamps in Scenario 2 notes that all components are imported from
China for the Wall Oven Lamps (Items 1 and 2). For the Apex Lamp (Item 3), all components except for the
ceramic socket will be imported from China, the ceramic socket will be produced in Thailand.
The final assembly procedures in Thailand involve manually combining the Thai-origin components and the
imported components via clamping and riveting machines.
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 two manufacturing scenarios for the products. We note that, in the first scenario, a
majority of components, including the halogen bulbs, glass lens, and sockets are imported from China. These
components make up the light source of the lamps. Furthermore, China-origin components contribute over 60
percent of the total cost in Items 1 and 2, and 75 percent in Item 3, with the halogen bulb alone accounting
for 26 to 30 percent of the total component cost depending on the lamp models. The manufacturing process is
not considered sufficiently “complex and meaningful” as to result in a substantial transformation in Thailand.
In the second scenario, all components are imported from China in Items 1 and 2, and only the socket in Item
3 is made in Thailand. The simple assembly of the imported components would not constitute a substantial
transformation because the assembly operations in Thailand are not sufficiently complex and meaningful to
result in a substantial transformation.
Accordingly, we find that the country of origin for the three oven lamps will be China in both scenarios for
the purposes of 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