The country of origin and applicability of Section 301 remedies regarding a combined coolant and refrigerant fluid distribution assembly

N343389 November 5, 2024 OT:RR:NC:N1:102 CATEGORY: Country of Origin Jeremy Page Page Fura, P.C. 939 W. North Avenue, Suite 750Chicago, IL 60642 RE:  The country of origin and applicability of Section 301 remedies regarding a combined coolant and refrigerant fluid distribution assembly Dear Mr. Page: In your letter dated October 17, 2024, you requested a country of origin ruling regarding a combined coolant and refrigerant fluid distribution assembly on behalf of Rivian Automotive LLC. Technical information was provided with your submission. The product under consideration is identified as a “Megabundle” which combines coolant and refrigerant fluid distribution subassemblies into a single imported assembly for incorporation into a Rivian-branded automotive vehicle. The primary function of the assembly is the consolidation of coolant and refrigeration fluid distribution and control. In addition to controlling the fluid direction and flow rate of the respective fluid types, the combined Megabundle assembly has the capability to exchange thermal energy to and from each subassembly. The final product, consisting of 44 individual Chinese-origin components, is assembled in Mexico after several distinct product preparation, testing, and packaging operations. After flushing the manifold block assembly with air, assembly begins when three refrigerant check valves are pressed into position using a calibrated compression tool. Three check valve retaining rings are then installed to ensure the check valves do not slip out of place. Next, four expansion valve cores are installed, each combined with a large and small O-ring. The following step in the process involves the installation of five refrigerant sensors and two refrigerant shutoff valve cores to precise torque, angle, and curvature. After that, a desiccant cartridge is press-forced into the accumulator bottle port using vision guidance equipment, and a service cap, snap-ring, and dust cover are assembled into place. With camera guidance, an upper mounting bracket is affixed to the manifold block before inner metal bushings and rubber bushings are inserted into place. Next, a leak test is performed to ensure all seals are tight. If the leak test is satisfactory, four refrigerant expansion valve coils are installed using camera guidance technology and associated valve coil seals are installed through pressing. Two refrigerant shutoff valve coils (high-side and low-side) are installed through pressing and fastening to specified torque and angle. Next, six refrigerant air conditioning line studs are screwed into the block assembly to support the flow of refrigerant through the system. After that, a wiring harness to establish connectivity and communicability of the block assembly is installed by hand for precision and stability. Interim testing of the block assembly and coolant manifold block is performed. If compliant, the coolant block is mounted to the back side of the block assembly with two gaskets and pressed into place across its surface using six fasteners torqued in unison. Utilizing two O-rings, the heat exchanger is mounted to the same side of the assembly as the coolant block and the entire unit is then pressed into the manifold block assembly using four fasteners and a tightening gun. At this stage, two coolant pumps and companion O-rings are pressed into designated locations on the coolant block assembly before being secured with eight fasteners per pump. A multi-way coolant valve, combined with five gaskets, an O-ring, and four fasteners, is installed after the valve’s electrical pin connectors are aligned with the coolant block body and then pressed into position. Next, five coolant temperature sensors are placed into respective locations on the valve plate before being pressed into place. Snap-rings are applied to each sensor for stability. Finally, wire harness terminals are connected, and the product is ready for final testing, inspection, and packaging. When determining the country of origin for purposes of applying current trade remedies under Section 301, 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). In order to determine whether a substantial transformation occurs when components of various origins are assembled into completed products, all factors such as the components used to create the product and manufacturing processes that these components undergo are considered. No one factor is decisive, and assembly operations that are minimal will generally not result in a substantial transformation. In determining whether the combining of parts or materials constitute a substantial transformation, the issue is the extent of operations performed and whether the parts lose their identity and become an integral part of a new article. In this instance, the assembly operations in Mexico are complex, consisting of multi-level assembly operations, which require a high degree of precision using specialized equipment, advanced technology, and rigorous testing. As outlined in your submission, the process requires mechanical assembly combined with robotics, camera guidance systems, automated quality assurance tools, and radio-frequency identification (RFID) and quick response (QR) code scanners. Furthermore, a sizeable and well-trained group of workers is required to carry out operations and assembly. It is our position that the assembly operations in Mexico result in the individual components from China losing their separate identities to become a new and different article of commerce, i.e., a combined coolant and refrigerant fluid distribution assembly (Megabundle). As such, for the purposes of Section 301 Trade Remedy applicability, we find that the country of origin of the Megabundle will be Mexico. Accordingly, the product will not be subject to the Section 301 Trade Remedy. 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 Paul Taylor at paul.m.taylor@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division