The country of origin of ignition coils for an automotive engine from Vietnam

N344129 December 10, 2024 OT:RR:NC:N2:201 CATEGORY: Origin Judy Li Four E'S Vietnam A1-3, VSIP Hai Duong Cam Dien Cam Giang District, Hai Duong Hanoi, 03620 Vietnam RE:  The country of origin of ignition coils for an automotive engine from Vietnam Dear Ms. Li: In your letter dated November 18, 2024, you requested a country of origin ruling determination on ignition coils for an automotive engine.  In your request, you state that the ignition coils are completely assembled, and all subassemblies are manufactured in Vietnam. In your request, you presented documents/slides and a video showing the production work done in Vietnam. The item under consideration is described as part number DFC1007R (Ignition Coil), which is used to provide electrical energy to the spark plugs.  This product includes a plastic housing, copper wire, plastic skeleton, iron core, module, and rubber boot.  Your procedure for producing the ignition coil is the following: Material inspected for material, key dimension, appearance “First in First out” of temperature & humidity control Primary skeleton winding of .60mm copper wire to wind for 154±1 cycles (primary winding machine) Secondary skeleton winding using 0.05mm copper wire to wind for 10000±100 cycles (secondary winding machine) Install the high voltage connector and mounting diode Install tinned copper wire (length of tinned cooper is 30mm) Welded diode Solder the tinned copper wire Coil conduction test Put the primary coil into the secondary; install in the position Put the iron core into the assembled coil Install magnetic steel and measure the installation direction of magnetic steel Welding the PCB module onto the plug; non-virtual welding, electric soldering iron Module install into the coil, and make the secondary and primary coil's terminal weld Apply the Kraft glue K-704B onto the plastic housing Assembled coil installed into the housing Semi-product energy testing 14v, 1.4ms (tested to ≥26mJ) Preheating before potting 105℃~120℃ 2H; put the semi-coils into the preheating oven for 2hrs Put epoxy resin into the coil, put the epoxy resin into the coil when the vacuum degree≤100Mbar Epoxy resin cured at 80℃ ~125℃8H curing for 8hrs Finished products inspected Packaged Put the finished products into the warehouse 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). With the facts and documentation presented, it is the opinion of this office that the Ignition Coil’s (Part # DFC1007R) components and subassemblies are substantially transformed during the manufacturing process in Vietnam and thus that the country of origin of the complete Ignition Coil for an automotive engine is Vietnam. 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 Matthew Sullivan at matthew.sullivan@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division