The country of origin of a garage door opener set

N345644 February 19, 2025 OT:RR:NC:N1:103 CATEGORY: Origin Brandon French Braumiller Law Group, PLLC 5220 Spring Valley Road, Suite 200Dallas, TX 75254 RE:  The country of origin of a garage door opener set Dear Mr. French: In your letter dated February 3, 2025, you requested a country of origin ruling on the EasyRoller14 Operator on behalf of your client, Automatic Technology America LLC. The EasyRoller14 Operator is identified as an automatic garage door opener for rolling sheet doors. It is intended for commercial applications and imported as a set containing a main operator unit, wall transmitter, remote control transmitters, and photo electric safety beams. The remote control transmitters are used to wirelessly open and close the rolling sheet door. The wall transmitter serves the same purpose but can operate as either a wired or wireless device. The components for the EasyRoller14 Operator set are consolidated, assembled, and programmed in Australia. The remote control transmitters, wall transmitter, and photo electric safety beams are sourced from China as pre-built units. The main operator unit contains a drive system to open or close the garage door. It is assembled in Australia using Chinese subassemblies, including a printed circuit board assembly, power drive assembly, support chassis assembly, light diffuser, and string handle assembly. These subassemblies are sourced from China in a preassembled condition. For example, the power drive assembly is a pre-built unit with a 600N DC clutch gear motor, transformer, EMI filter board, and power cord installed in a plastic housing. The support chassis assembly arrives in Australia in a similar condition, with a timing assembly, rope buckle, and more, installed in a housing. In Australia, firmware is loaded onto the printed circuit board assembly for the main operator unit. Next, a worker connects the power drive assembly, transformer, timing assembly, power cord assembly, beam connector, and light diffuser assembly to the printed circuit board assembly. These steps are largely described as feeding wires, completing electrical connections, installing support plates, fitting pieces in place, attaching covers, and securing the subassemblies using fasteners or cable ties. Afterwards, the handle string is attached and tested. The resulting subassembly is placed inside a plastic housing and the entire unit is tested. The remote control transmitters and wall transmitter are programmed and coded to the main operator unit before the individual items are packaged together for shipment. 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 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 your request, you contend that the printed circuit board assembly in the main operator unit imparts the essential character to the set, and that the programming and loading of firmware to a Chinese printed circuit board assembly results in a substantial transformation. When the printed circuit board assembly arrives in Australia, it is already populated with the necessary electrical components and electrical connectors (e.g., terminal blocks, headers, jumpers, etc.) for a corresponding subassembly. These subassemblies arrive in Australia ready for final assembly and incorporate components that are critical to the unit’s function, such as the gear and motor assembly, clutch assembly, and more. In our view, the subsequent operations that occur in Australia do not change the foreign subassemblies. Thus, based on the totality of the circumstances, the country of origin of the EasyRoller14 Operator set, as described above, will be China. 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 Huang at paul.huang@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division