H351125

H351125 August 15, 2025 OT:RR:CTF:VS H351125 AP CATEGORY: Valuation Jackson Ko, Vice President Marketing Department Whole Space Industries Co. Ltd. 400 West Main Street Babylon, New York 11702 RE: PVC Cordless Mini Blinds; U.S. Content; 9903.01.34, HTSUS Dear Mr. Ko: This is in response to your July 30, 2025 ruling request, on behalf of Ever Ease International Ltd. (“Ever Ease”), asking whether polyvinyl chloride (“PVC”) suspension resin SE800 (“PVC resin”) used to make 1” light filtering PVC cordless mini blinds, 2” faux wood PVC cordless mini blinds, and 3.5” room darkening vertical PVC cordless mini blinds (collectively “mini blinds”) in Vietnam qualifies for the exemption under subheading 9903.01.34, Harmonized Tariff Schedule of the United States (“HTSUS”), and Chapter 99, Subchapter III, U.S. Note 2(v)(xiii), HTSUS. The requester has asked that certain information submitted in connection with this ruling be treated as confidential. Inasmuch as this request conforms to the requirements of 19 C.F.R. § 177.2(b)(7), the request for confidentiality is approved. The information contained within brackets in this ruling or in the attachments to the ruling request, forwarded to our office, will not be released to the public and will be withheld from published versions of this ruling. FACTS: Ever Ease is a supplier of window coverings servicing customers in the United States. It is a subsidiary of Whole Space Industries Ltd., which owns a factory in Vietnam. The factory in Vietnam manufactures 1” light filtering PVC cordless mini blinds, 2” faux wood PVC cordless mini blinds, and 3.5” room darkening vertical PVC cordless mini blinds in different sizes that will be imported into the United States from Vietnam. All components of the mini blinds will be made and assembled in Vietnam from PVC suspension resin SE800 manufactured in the United States. The U.S. PVC resin will be compounded with other ingredients in Vietnam to make PVC compound in the form of pellets. The pellets will be extruded into the mini blind components, such as the slats. The PVC compound will consist of U.S. PVC resin, another material [X], and other additives. The remaining percentage of the blinds includes other costs (i.e., ladder strings and cords, packaging materials, labor costs, overhead). The requester has determined the U.S.- made PVC content percentage of the mini blinds by multiplying the U.S. PVC resin portion of the PVC compound by the percentage of PVC compound in the mini blind, which varies for each mini blind depending on its type and size. The U.S. content is calculated by multiplying the fixed U.S. made PVC percentage under the proprietary formula by the PVC compound percentage. As an example of the contemplated transactions, the requester has provided the following information for the blinds: • 1” light filtering PVC cordless mini blinds The requester arrived at the total price paid or payable for the 1” light filtering PVC cordless mini blinds by adding the U.S. PVC content (34 percent), the cost of the [X] and other additives ([X] percent), and the other costs for ladder strings and cords, packaging materials, labor and overhead ([X] percent). Size Others % PVC U.S. FOB $ U.S. PVC [X] and Other Others $ Compound % Made Content $ Additives $ PVC % 23” x 64” [X]% [X]% 31% $[X] $[X] $[X] $[X] 27” x 64” [X]% [X]% 33% $[X] $[X] $[X] $[X] 29” x 64” [X]% [X]% 33% $[X] $[X] $[X] $[X] 31” x 64” [X]% [X]% 34% $[X] $[X] $[X] $[X] 34” x 64” [X]% [X]% 35% $[X] $[X] $[X] $[X] 35” x 64” [X]% [X]% 35% $[X] $[X] $[X] $[X] 36” x 64” [X]% [X]% 35% $[X] $[X] $[X] $[X] 39” x 64” [X]% [X]% 35% $[X] $[X] $[X] $[X] Total: $[X] $[X] $[X] $[X] (34%) ([X]%) ([X]%) • 2” faux wood PVC cordless mini blinds The requester arrived at the total price paid or payable for the 2” faux wood PVC cordless mini blinds by adding the U.S. PVC content (29 percent), the cost of the [X] and other additives ([X] percent), and the other costs for ladder strings and cords, packaging materials, labor and overhead ([X] percent). Size Others % PVC U.S. FOB $ U.S. PVC [X] and Other Others $ Compound % Made Content $ Additives $ PVC % 27” x 64” [X]% [X]% 29% $[X] $[X] $[X] $[X] 29” x 64” [X]% [X]% 29% $[X] $[X] $[X] $[X] 30” x 64” [X]% [X]% 29% $[X] $[X] $[X] $[X] 31” x 64” [X]% [X]% 29% $[X] $[X] $[X] $[X] 33” x 64” [X]% [X]% 29% $[X] $[X] $[X] $[X] 35” x 64” [X]% [X]% 30% $[X] $[X] $[X] $[X] 36” x 64” [X]% [X]% 30% $[X] $[X] $[X] $[X] Total: $[X] $[X] $[X] (29%) ([X]%) ([X]%) 2 • 3.5” room darkening vertical PVC cordless mini blinds The requester arrived at the total price paid or payable for the 3.5” room darkening vertical PVC cordless mini blinds by adding the U.S. PVC content (31 percent), the cost of the [X] and other additives ([X] percent), and the other costs for ladder strings and cords, packaging materials, labor and overhead ([X] percent). Size Others % PVC U.S. FOB $ U.S. PVC [X] and Other Others $ Compound % Made Content $ Additives $ PVC % 42” x 63” [X]% [X]% 28% $[X] $[X] $[X] $[X] 54” x 63” [X]% [X]% 29% $[X] $[X] $[X] $[X] 66” x 63” [X]% [X]% 29% $[X] $[X] $[X] $[X] 78” x 63” [X]% [X]% 30% $[X] $[X] $[X] $[X] 66” x 84” [X]% [X]% 32% $[X] $[X] $[X] $[X] 78” x 84” [X]% [X]% 33% $[X] $[X] $[X] $[X] 90” x 84” [X]% [X]% 33% $[X] $[X] $[X] $[X] 104” x 84” [X]% [X]% 33% $[X] $[X] $[X] $[X] Total: $[X] $[X] $[X] $[X] (31%) ([X]%) ([X]%) Furthermore, the exemplar information indicates that the factory in Vietnam purchased [X] metric tons (“MT”) of U.S. PVC resin priced at $[X] per MT for a total price of $[X] from a seller in Singapore who in turn purchased it from U.S. manufacturer [X] located in the United States. Ever Ease submitted proof of payment. The port of loading was in the United States at [X, X], and the place of delivery was Haiphong Port, Vietnam. The Incoterms were “CIF, Haiphong, Vietnam.” The packing list reveals that [X] MT of PVC resin ([X] bags) produced by the U.S. manufacturer [X] were shipped from the United States at [X, X] to Haiphong, Vietnam, on June 28, 2025. According to the bill of lading, the shipper/exporter was the U.S. manufacturer [X] and [X] bags of resin ([X] MT) departed from the United States at [X, X] to Haiphong, Vietnam on June 28, 2025. The U.S. manufacturer issued a certificate of analysis dated June 28, 2025, to the requester to verify the resin’s quality and compliance with specified standards. The June 28, 2025 certificate of origin from the U.S. manufacturer’s forwarding agent certifies that the exported [X] MT of resin manufactured in the United States are “products” of the United States. The total price paid or payable for the mini blinds on the invoices represents the customs value. The commercial invoice from Ever Ease to the U.S. customer [X] for the 1” light filtering PVC cordless mini blinds reveals that the light filtering mini blinds produced in Vietnam will be shipped from Vietnam to the United States, and the Incoterms will be “FOB Haiphong, Vietnam.” The U.S. customer will serve as the U.S. importer of record. The total price paid or payable for [X] 1” light filtering PVC cordless mini blinds will be $[X]. The commercial invoice from Ever Ease to the U.S. customer for the 2” faux wood PVC cordless mini blinds reveals that the faux wood mini blinds produced in Vietnam will be shipped from Vietnam to the United States, and the Incoterms will be “FOB Haiphong, Vietnam.” The total price paid or payable for [X] 2” faux wood PVC cordless mini blinds will be $[X]. Ever Ease has not yet issued an invoice to the U.S. customer for the 3.5” room darkening vertical PVC cordless mini blinds. You advised that the total price paid or payable for the room darkening vertical mini blinds will be $[X]. 3 ISSUE: Whether the U.S.-origin PVC resin used to produce the 1” light filtering PVC cordless mini blinds, the 2” faux wood PVC cordless mini blinds, and the 3.5” room darkening vertical PVC cordless mini blinds qualifies for the U.S. content exemption under subheadi

Effective April 5, 2025, Presidential Executive Orders implemented “Reciprocal Tariffs.” See Exec. Order No. 14257, 90 Fed. Reg. 15041 (Apr. 2, 2025); Exec. Order No. 14266, 90 Fed. Reg. 15509 (Apr. 9, 2025); Exec. Order No. 14316, 90 Fed. Reg. 30823 (July 7, 2025); and Exec. Order No. 14326, 90 Fed. Reg. 37963 (July 31, 2025). These additional tariffs apply to imported goods of most countries, including Vietnam. All imported merchandise subject to these Executive Orders must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exemptions to the reciprocal tariffs. As of the date of this ruling, imports from Vietnam are subject to additional duties under subheading 9903.01.25, HTSUS, which states: Articles the product of any country, except for products described in headings 9903.01.26–9903.01.33, 9903.02.02–9903.02.71, and 9903.96.01, and except as provided for in headings 9903.01.34 and 9903.02.01, as provided for in subdivision (v) of U.S. note 2 to this subchapter. Subheading 9903.01.34, HTSUS, which is an exemption from the additional duties, states: The U.S. content of articles the product of any country, in which the U.S. content of the article provides at least 20 percent of the Customs value of the imported article, as provided for in subdivision (v)(xiii) of U.S. note 2 to this subchapter. Chapter 99, Subchapter III, U.S. Note 2(v)(xiii), HTSUS, states: The additional duties imposed by headings 9903.01.25, 9903.01.35, 9903.01.39, 9903.01.63, and 9903.02.01-9903.02.71 shall not apply to the U.S. content of an article, provided at least 20% of the customs value, as determined under 19 U.S.C. 1401a, of the product is U.S. originating, consistent with heading 9903.01.34. For greater certainty, with respect to an article for which at least 20% of the customs value is U.S. originating, consistent with 9903.01.34, the additional duties imposed by headings 9903.01.25, 9903.01.35, 99