China components, manufacturing in Vietnam: what CBP actually ruled
19 country-of-origin decisions, 2018–2026, extracted from CBP rulings into a comparable form. 7 kept China origin.
7
stayed China: the move did not work
11
became Vietnam
37%
failure rate for the move
Why this page exists. CBP publishes these rulings individually and its search
returns them one at a time. It cannot tell you how many decisions exist for a sourcing
structure, which way they went, or what separated them. Those are the only questions
that matter when you are deciding where to manufacture, so they are what this page
answers, from 19 decided cases, each linked to the original.
What separated them
Comparing the work actually performed in Vietnam across both groups:
Present when origin moved to Vietnam
mold, cure, forg, smt, injection: operations that appear in the Vietnam-origin cases and in none of the cases that stayed China.
Typical of cases that stayed China
assembl, paint, test, polish, pack, screw: the operations CBP repeatedly describes as simple assembly or finishing.
This grouping is ours, not CBP's. The outcome shown for every case below is CBP's own determination. The split above is a summary of the operations involved, offered to orient you. Substantial transformation is decided case by case on the totality of the facts, and a matching operation does not predict a matching result.
Cases where origin stayed China
These are the ones worth reading first: the manufacturing moved and CBP still found China origin.
N346005: vent free freestanding gas log model VL-EO18DL
Vietnam laser cutting
Vietnam bending forming
Vietnam painting
Vietnam silk printing
Vietnam assembling
Vietnam tightening
Based on the documents presented, we find that the majority of the parts or components are from China, especially the components imparting the character, including the ignitor, burner assembly, and logs originate in China, and the majority of value comes from
Based on the documents presented, we find that the majority of the parts or components are from China, especially the components imparting the character, including the ignitor, burner assembly, and logs originate in China, and the majority of value comes from
N346005: vent free freestanding gas log model VFL3-EO18DTL
Vietnam laser cutting
Vietnam bending forming
Vietnam painting
Vietnam silk printing
Vietnam assembling
Vietnam tightening
Based on the documents presented, we find that the majority of the parts or components are from China, especially the components imparting the character, including the ignitor, burner assembly, and logs originate in China, and the majority of value comes from
Based on the documents presented, we find that the majority of the parts or components are from China, especially the components imparting the character, including the ignitor, burner assembly, and logs originate in China, and the majority of value comes from
N346005: vent free freestanding stove model VSF2-MF30DT
Vietnam laser cutting
Vietnam bending forming
Vietnam painting
Vietnam silk printing
Vietnam assembling
Vietnam tightening
Based on the documents presented, we find that the majority of the parts or components are from China, especially the components imparting the character, including the ignitor, burner assembly, and logs originate in China, and the majority of value comes from
Based on the documents presented, we find that the majority of the parts or components are from China, especially the components imparting the character, including the ignitor, burner assembly, and logs originate in China, and the majority of value comes from
N342448: Noodle Hand Towel
China Polyester tufted and knit fabrics are formed.
China Fabrics are cut.
China Tufted fabric is sewn, with spider legs (Item #EG2409002) or without (Item #EG
China Assembled shells are exported to Vietnam.
Vietnam The foam is formed.
Vietnam Narrow woven cotton fabric is formed.
Left China as: tufted fabric shell with an opening left to fill
The fabrics used to make the shell of the puff and spider legs are formed by the fabric-making process in China and the narrow woven cotton fabric hanging loop is formed in Vietnam.
You have stated that the woven fabric forming the hanging loop is not more than 7 percent of the total weight of the good for both item #EG2409001 and item #EG2409002; therefore, the narrow woven cotton fabric is disregarded in determining the country of origi
N342448: Noodle Hand Towel With Spider Legs
China Polyester tufted and knit fabrics are formed.
China Fabrics are cut.
China Knit fabric is sewn and filled with fiber fill to create spider legs (Item #EG
China Tufted fabric is sewn, with spider legs (Item #EG2409002) or without (Item #EG
China Assembled shells are exported to Vietnam.
Vietnam The foam is formed.
Left China as: tufted fabric shell with spider legs and an opening left to fill
The fabrics used to make the shell of the puff and spider legs are formed by the fabric-making process in China and the narrow woven cotton fabric hanging loop is formed in Vietnam.
You have stated that the woven fabric forming the hanging loop is not more than 7 percent of the total weight of the good for both item #EG2409001 and item #EG2409002; therefore, the narrow woven cotton fabric is disregarded in determining the country of origi
N339907: Large Framed Wall Mirror
Vietnam cut to size
Vietnam the edges are polished
Vietnam cut to shape
Vietnam used to frame the mirrors
Vietnam assembled
Vietnam screwed to the back of the frame
Left China as: unframed mirror glass sheets
This office finds that the essential character of the Large Framed Wall Mirror is imparted by the glass mirror.
The glass mirror accounts for the greater bulk and provides the role of a constituent material in relation to the use of the good rather than the components made of other materials.
Cases where origin became Vietnam
N359281: pop-up drain assembly
Vietnam aligning
Vietnam manually screwed
Vietnam manually positioned and pressed into position
Vietnam screwed onto
Vietnam pressed onto
Vietnam applied and cured
Here, the processes that occur in Vietnam are simple and do not constitute a substantial transformation.
The assembly and packaging processes performed in Vietnam do not change the shape, character, or predetermined use of the inputs.
N358953: aluminum radiator
Vietnam cut and rolled into flat tube profiles of the required width
Vietnam high frequency brazed along the seam
Vietnam cut to length and inspected for dimensional accuracy
Vietnam fed into a roll-forming machine to create the desired fin geometry
Vietnam cut to precise dimensions and stacked for core assembly
Vietnam quality control checks for uniform thickness, shape, and spacing
Left China as: aluminum rolls
Similarly in this case, the Chinese aluminum rolls and sheets are substantially transformed in Vietnam into tubes and fins, which are eventually assembled into the core.
The final assembly of all components also occurs in Vietnam.
N351504: PTC fan heaters
Vietnam production of plastic parts from plastic raw materials
Vietnam plastic injection molding
Vietnam adhering the ceramic heating sheet and the thermal conductive strip together
Vietnam electric curing the PTC heating element
Vietnam adding connectors
Vietnam conducting multiple tests to confirm the product is functioning correctly
Left China as: raw materials
This office reviewed the provided assembly process flow charts and other materials in the submission, and is of the opinion that the Chinese components undergo processing in Vietnam that is sufficiently complex and meaningful as to result in a substantial tran
This office reviewed the provided assembly process flow charts and other materials in the submission, and is of the opinion that the Chinese components undergo processing in Vietnam that is sufficiently complex and meaningful as to result in a substantial tran
N351597: positive temperature coefficient (PTC) Fan Heater II (“PTC
Thailand adhering the ceramic sheet and the conductive thermal strip
Vietnam plastic injection molding operations
Vietnam place the Vietnamese-produced body components, the Thai-produced PTC heating e
Vietnam manufacturing/assembly
Vietnam inspection and testing
Vietnam packaging
We reviewed the provided assembly process flow charts and other materials in the submission, and is of the opinion that the Chinese-origin and the Thai-origin components undergo processing in Vietnam that is sufficiently complex and meaningful as to result in
We reviewed the provided assembly process flow charts and other materials in the submission, and is of the opinion that the Chinese-origin and the Thai-origin components undergo processing in Vietnam that is sufficiently complex and meaningful as to result in
N350622: 2nd Generation Wheel Hub Bearing Assembly
Vietnam ground, turned, demagnetized, and heat treated to required diameters and measu
Vietnam drilled and tapped
Vietnam cleaned
Vietnam press-fit
Left China as: rough-cut inner ring
Since the inner rings from China become races with precision raceways in Vietnam and the flange is made in Vietnam, the country of origin of the APT-Gen-2-WHB (Part Number 980901A) will be Vietnam for marking purposes and for purposes of applying current trade
Since the inner rings from China become races with precision raceways in Vietnam and the flange is made in Vietnam, the country of origin of the APT-Gen-2-WHB (Part Number 980901A) will be Vietnam for marking purposes and for purposes of applying current trade
N350622: 2nd Generation Wheel Hub Bearing Assembly
Vietnam ground, turned, demagnetized, and heat treated to required diameters and measu
Vietnam spline broaching
Vietnam drilling and tapping of holes
Vietnam cleaned
Vietnam press-fit
Left China as: rough-cut inner ring
Furthermore, the splining feature of the APT-Gen-3-WHB gives the wheel hub a functionality beyond a bearing.
It allows the wheel hub to mesh with the drive axle to transmit torque.
All 19 decisions
| Ruling | Date | Product | CBP held |
|---|---|---|---|
| N362121 | 2026-06-26 | paint sprayer | Thailand |
| N359281 | 2026-03-25 | pop-up drain assembly | Vietnam |
| N358953 | 2026-03-10 | aluminum radiator | Vietnam |
| N351504 | 2025-08-15 | PTC fan heaters | Vietnam |
| N351597 | 2025-08-15 | positive temperature coefficient (PTC) Fan Heater II ( | Vietnam |
| N350622 | 2025-07-21 | 2nd Generation Wheel Hub Bearing Assembly | Vietnam |
| N350622 | 2025-07-21 | 2nd Generation Wheel Hub Bearing Assembly | Vietnam |
| N346005 | 2025-03-07 | vent free freestanding gas log model VL-EO18DL | China |
| N346005 | 2025-03-07 | vent free freestanding gas log model VFL3-EO18DTL | China |
| N346005 | 2025-03-07 | vent free freestanding stove model VSF2-MF30DT | China |
| N343501 | 2024-11-22 | ratchet tie-downs | Vietnam |
| N342448 | 2024-09-24 | Noodle Hand Towel | China |
| N342448 | 2024-09-24 | Noodle Hand Towel With Spider Legs | China |
| N342421 | 2024-09-11 | Automotive Primary Wire | Vietnam |
| N339907 | 2024-05-30 | Large Framed Wall Mirror | China |
| N326538 | 2022-06-24 | SKU#243734 HUSKY 21oz Framing Hammer | Vietnam |
| N308511 | 2020-01-15 | Battle Buds | Vietnam |
| N304773 | 2019-07-01 | stainless steel drawn sinks | China |
| N300248 | 2018-08-30 | furniture parts | Vietnam |
1 of these resolved to a country other than China or Vietnam, usually a third country in the supply chain.
Does this answer your case?
This page covers China → Vietnam. If your structure is different (other countries, other operations, a component you are unsure about), describe it and I will look for the closest decided CBP cases and send them back.
Method
Every CBP ruling that decides country of origin and mentions both China and Vietnam was read and converted into a structured record: the components and where they came from, each manufacturing step and the country it happened in, and the determination CBP reached. A case appears above when it has at least one China-origin component and at least one operation performed in Vietnam. Counts are of scenarios, not rulings: a single ruling often presents several alternative structures, and CBP can reach different conclusions for each.
Quotes are verbatim from the ruling text. Figures are as of the last-updated date below.
Not legal advice, and not a determination. A CBP ruling binds only the party who
requested it, on the facts they presented. Substantial transformation is fact-specific.
Use these as precedent to understand how CBP has reasoned, then get a binding
ruling or advice from a licensed customs broker or trade attorney for your own goods.