The country of origin and applicability of Section 301 Trade Remedies of Junction Blocks

N344206 December 10, 2024 OT:RR:NC:N2:220 CATEGORY: Origin; Trade Remedies Byeoung Ho Park SEIN Customs & Auditing Corp 138, Seoun-ro, Seocho-gu Seoul  06619 South Korea RE:      The country of origin and applicability of Section 301 Trade Remedies of Junction Blocks Dear Mr. Park: In your letter dated November 22, 2024, you requested a country of origin ruling on behalf of your client, Hyundai Motor Company. There are two items under consideration that are identified as the Junction Block Assy-HI/VLT, PN 91958-DS030 and PN 91958-DO310, which are both described as an enclosure with internally mounted fuses, bus bars, a relay, wiring, and hardware.  The Junction Blocks are used in electric vehicles to provide high voltage electrical connections between the vehicle electrical systems and the high powered inverter. In your letter, you state that the relay is sourced from Japan, while the balance of all materials used in the manufacturing of the Junction Blocks, such as the fuses, the bus bars, the enclosure, and the hardware, are sourced from Korea.  In Korea, the electrical apparatus and wire are mounted inside the enclosure and bolted in place, the Junction Blocks are inspected, tested, and packaged for export to the United States. Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Regarding the country of origin of the Junction Blocks, in our view, the assembly operations performed in Korea, which consists mainly of inserting and fastening the components into a housing, are neither complex nor do they substantially transform the articles being assembled. However, it is the opinion of this office that the Korean origin bus bars and fuses produce the function of the device because they are the articles within the assembly that are making the electrical connections between the vehicle’s inverter and the electric motor(s).  While the Japanese origin electrical relay also contributes to the electrical connection function, it is our position that the fuses and bus bars, in sum with the assembly operations in Korea, establish the origin of the finished Junction Blocks as electrical connection apparatus.  Therefore, based upon the facts presented, the Junction Block Assy-HI/VLT, PN 91958-DS030 and PN 91958-DO310 are considered products of Korea for origin and marking purposes at time of importation into the United States.  Lastly, as no components are of Chinese origin, nor is any assembly work conducted in China, the Junction Blocks are not subject to Section 301 trade remedies upon importation into the United States. 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 Karl Moosbrugger at karl.moosbrugger@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division