OT:RR:NC:N5:121
Based on the documents presented, we find that the majority of the parts or components are from China, especially the components including the ignition, motor assembly, and PCB, and the majority of the value comes from China. The parts manufactured in Vietnam enclose and enhance these Chinese components. Further, although the Vietnam assembly process involves some complex operations to an extent, the majority appear simple in nature, such as punch forming, welding, painting, assembling, connecting, and testing. As the Chinese components undergo a simple assembly process to form the completed forced air heater and are not changed to the point that they emerge with a new name, character, or use that is different from what they possessed prior to processing, it is our opinion that they are not substantially transformed in Vietnam. Therefore, it is our view that the country of origin of the propane forced air heater, model number LPFA60TS is China for purposes of current Section 301 and Section 232 duties. 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 Jennifer Jameson at [email protected].
Sincerely,
Steven A. Mack Director National Commodity Specialist Division