The country of origin of position sensors

N345997 February 27, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Christine Cai Aborn Automotive Sensor (Thailand) CO., LTD. 475/5 Moo 7, T. Klong KiewA.Ban Bueng Thailand RE:  The country of origin of position sensors Dear Ms. Cai: In your letter dated February 17, 2025, you requested a country of origin ruling. The merchandise under consideration, identified by part number 20030147, is described as a crankshaft/camshaft position sensor for use in vehicles. The subject device is comprised of an electromagnetic core within a housing with a connector at one end. You state that the devices are used within the engine compartment of a vehicle and provide position and speed of the camshaft and crankshaft of the vehicle. This information is gathered by the Electronic Control Unit (ECU) of the vehicle for interpretation. The devices function as a transducer by creating a magnetic field that, when broken by the presence of a metal object (i.e. the engine part), creates and electrical signal that is then sent to the ECU. In your request, you state that the manufacturing process occurs entirely in Thailand. The process begins with German originating enameled wire being wrapped around the plastic coil frame, which also incorporates the electrical connection portion of the device and originates in Thailand. A magnet, also originating from Thailand, is then attached along with an iron core. This assembly is then encased within a plastic enclosure before it is inspected, tested, and packaged for shipment to the U.S. When determining the country of origin, 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). Regarding the origin of the subject sensor, it is the opinion of this office that the enameled wire is substantially transformed by the process performed in Thailand. Further, the magnetic and electrical capabilities, which impart the character of the device, are added by these processes. Based upon the facts presented, the origin of the crankshaft/camshaft position sensor, part number 20030147, will be Thailand.  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 Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division