OT:RR:NC:N4:410
Michael Murphy
Sidley Austin LLP
1501 K Street NW
Washington, D.C., DC 20005
RE: The country of origin of electric steam irons
Dear Mr. Murphy:
In your letter dated September 20, 2026, on behalf of Spectrum Brands, Inc., you requested a country of
origin ruling on electric garment irons for purposes of current trade remedies.
The product involved here is the Black & Decker Easy Steam Nonstick Iron (the “iron”). This garment steam
iron is used to heat and flatten garments, thereby eliminating any wrinkles or creases in the fabric.
The iron is assembled in Vietnam using components manufactured in China and Vietnam. The
Chinese-origin components include the soleplate, PCB (Printed Circuit Board), thermostat, inner wires,
bimetal chip, and connectors. The balance of components are produced in Vietnam, which include the whole
product assembly, water tank assembly (including the water tank), lower handle, water tank bottom, top and
front covers, skirt, and lamp cover.
The soleplate is manufactured in China, where its substrate is die-cast, polished, coated, and assembled with
a quartz tube that heats the finished soleplate. Next, the soleplate, along with other Chinese-origin
components, is shipped to Vietnam. In Vietnam, various plastic parts are injection-molded. A steam cover is
then attached to the soleplate with a pressing and forming machine, and room-temperature vulcanizing glue is
applied. The soleplate is then welded and screwed to the various other components, including the
injection-molded plastic parts, a printed circuit board, a water tank assembly, and a power cord, to create the
final iron. You state that the manufacturing process in Vietnam involves operations to snap the parts together,
secure them with screws, and package the finished product for retail sale.
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).
We note that the solesplates are fabricated in China. They are the most important or critical, as well as the
single most expensive components of the subject electric steam irons, which also impart the character of the
electric steam iron. In addition, a significant number of components are also produced in China. Although the
factory in Vietnam produces certain components and its assembly involves some complex steps, the majority
of the processes are simple in nature. The operations in Vietnam do not substantially transform the
solesplates.
Accordingly, we believe that the country of origin for the electric steam irons will be China 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