NY N364814: RE: The tariff classification and country of origin of iron decorative garden statues

Native CBP ruling rendition. Applicability is fact-specific; modification/revocation relationships and original publisher date are retained. Publisher sentinel year0001 means unknown date, not a historical legal adoption.

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364814 September 25, 2026 CLA-2-83:OT:RR:NC:N5:121 CATEGORY: Classification; Origin TARIFF NO.: 8306.29.0000 Olivia Lai Viittion (Asia) Limited Flat/RM D03, Blk A, 12/F, Universal Industrial Centre 19-25 Shan Mei ST Shatin, Hong Kong RE: The tariff classification and country of origin of iron decorative garden statues Dear Ms. Lai: In your letter dated September 2, 2026, you requested a tariff classification and country of origin determination ruling. Photographs and descriptions of the merchandise and manufacturing process were included in your inquiry. The articles under consideration are four large-size iron decorative garden statues. They are described as a 6-foot Cowboy Rooster, SKU#6104651RS; a 74-inch Americana Rooster, SKU#6109768RS: a 6-foot Floral Rooster Blue, Item number 6124258; and a 6-foot Black and White Rooster, Item number 6109769. Each statue is made of iron, shaped into a large-size rooster, and painted. They are intended for outdoor home and garden seasonal decoration. You describe a manufacturing process in which these statues are manufactured using iron sourced from China that is shipped to Cambodia. In Cambodia the iron is stamped, cut, welded, ground, pickled and phosphated, powder coated, color painted, and then assembled and packaged. The applicable subheading for the iron decorative garden statues, SKU#6104651RS, SKU#6109768RS, Item number 6124258, and Item number 6109769 will be 8306.29.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Bells, gongs and the like, nonelectric, of base metal; statuettes and other ornaments, of base metal; photograph, picture or similar frames, of base metal; mirrors of base metal; and base metal parts thereof: Statuettes and other ornaments, and parts thereof: Other. The general rate of duty will be Free. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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). Based on the provided documentation, these decorative garden statues are made using iron of Chinese origin that is manufactured into the completed articles entirely in Cambodia. All of the manufacturing of the rooster’s head, comb, wings, body, and tail by means of stamping, welding, grinding, pickling, phosphating, powder coating and assembling of the product takes place in Cambodia. As the raw iron from China is processed in Cambodia and afterwards emerges with a new name, character, and use that is different from what it possessed prior to processing, thus completing a substantial transformation, the country of origin in this scenario would be Cambodia. 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 jennifer.d.jameson@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division