The country of origin of fuel modules

N346435 March 26, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Jessica Xie Jinjia Electronic Technology (Thailand) Co., Ltd 60 Village No. 3, Hang Sung Subdistrict, Nong Yai District, Chonburi Province, Nong Yai 20190 Thailand RE: The country of origin of fuel modules Dear Ms. Xie: In your letter dated March 4, 2025, you requested a country of origin ruling on fuel modules. Descriptive information was provided with your submission. The products at issue are referred to as a fuel pump and fuel modules, identified by model numbers JINJIA-A75-13, JINJIA-A803-14, JINJIA-A779, JINJIA-A195ZL and JINJIA-B7. The modules primarily consist of a fuel pump, a float arm, a wiper seat. an ROV valve, a pressure sensor, a reservoir with a jet pump, and a resistance card seat. The fuel pump and the additional components work together to deliver fuel from the fuel tank to the engine management system. In regard to origin, you explain that components from China and Thailand are assembled together to form subassemblies. The subassemblies are then combined with one another to form the final product. The processes that produce the subassemblies and the final assembly processes occur in Thailand. For the flange subassembly, a supply tube is pressed on the flange and fastened in place. An O-ring is then installed, a support rod is pressed onto the flange, and a spring support is installed onto the support rod. Tests are completed throughout the steps. For the reservoir subassembly, a filter element and cover are welded into the filter bucket. Next a pressure regulator is inserted into the regulator seat of the filter. The buckle is locked, and a hose is pressed onto the filter’s pipe outlet. The filter and pump are pressed into their respective holder and locked in placed. Afterwards, the strainer is connected to the pump’s inlet pipe and the pump holder with the contained components are pressed into the reservoir. Subsequently, an O-ring is installed, and the wire harness is appropriately welded. A check valve is assembled, and then the valve and a spring are installed into a jet pump, which is subsequently installed into the reservoir. For the resistance subassembly, the resistance card is assembled to the wiper seat. For the float arm subassembly, a float, a float block and washer are assembled to each other. Once the aforementioned subassemblies are complete, the final assembly of the fuel modules occurs. During the final assembly, the flange subassembly is inserted into the reservoir subassembly. Next, the resistance subassembly and the float subassembly are secured onto the reservoir subassembly and buckled in place. The difference between the five products is the origin of the components. For JINJIA-A195ZL, the Chinese components are a dust cover (part number 405021010062), a pressure sensor, a ROV valve, a support rod and spring, a strainer, a resistance card, a float arm, and a wire harness. For JINJIA-A75-13, the Chinese components are a flange, a support rod and spring, a strainer, a float arm, a resistance card, a contact point and a wire harness. For JINJIA-A779, the Chinese components are a flange, a support rod and spring, a pressure regulator, a resistance card, a float arm, and a wire harness. For JINJIA-A803-14, the Chinese components are a flange, a support rod and spring, a pressure regulator, a resistance card, and a wire harness. For the JINJIA-B7, the Chinese components are an armature and an impeller. The remaining components for the five products are produced in Thailand. 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). Here, components from China and Thailand assembled together in Thailand to produce subassemblies, which are then combined with one another to form the complete module. When considering the totality of the circumstances, this office finds that the assembly processes that will occur in Thailand, taken as a whole, are sufficiently complex and meaningful as to result in a substantial transformation, such that the non-originating components lose their individual identities and become an integral part of a new article, possessing a new name, character and use. Based on the subassembly and final assembly processes described in the submission, we find that the country of origin of the fuel modules is Thailand. Accordingly, the country of origin of the fuel pump and fuel modules, identified as JINJIA-A75-13, JINJIA-A803-14, JINJIA-A779, JINJIA-A195ZL and JINJIA-B7, for the purpose of Section 301 Trade Remedies is 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 Sandra Martinez at sandra.martinez@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division