The country of origin of an ignition coil for an automotive engine

N347207 April 30, 2025 OT:RR:NC:N2:201 CATEGORY: Origin Judy Li FOUR E'S VIET NAM CO., LTD Factory A1-3, Lot 2, Cam Dien, Luong Dien Industrial Park, Phuc Dien Commune, Cam Giang District Hai Duong Province, Hanoi Vietnam RE: The country of origin of an ignition coil for an automotive engine Dear Ms. Li: In your letter dated March 31, 2025, you requested a country of origin ruling determination on an ignition coil for an automotive engine on behalf of your client, Spectra Premium Mobility Solutions, Greenfield, Indiana. In your request, you state that the ignition coils are completely assembled in Vietnam from Chinese and Vietnamese components. You presented documents/slides and a video showing the production work done in Vietnam. The item under consideration is described as an Ignition Coil, Part # UF569. An Ignition Coil is used to provide electrical energy to the spark plugs in order to initiate the “spark-ignition” internal combustion. 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: Primary winding of 124 ± 1 turns with 0.41mm pure copper enameled wire. Chinese Origin Wire, incorporated into Ignition Coil in Vietnam Wrap the primary coil with tape - wrap a circle with 12*0.06mm polyimide tape. Winding of secondary coils - Use 0.04 copper enameled wire to wind 9000 ±100 turns. Chinese Origin Wire, incorporated into Ignition Coil in Vietnam Soldering of the secondary coil - Soldering is carried out using an electric soldering iron at a temperature ranging from 400 to 420. Conduction test of the secondary coil. Performed in Vietnam Assemble the primary coil and the secondary coil. Performed in Vietnam Install the core and magnetic steel. Chinese Origin Iron Core, incorporated into Ignition Coil in Vietnam Assemble the core, magnetic steel and coil together. Performed in Vietnam Install the iron core gasket and phosphor bronze spring wire. Chinese Origin Gasket and Bronze Spring, incorporated into Ignition Coil in Vietnam Insert the assembled coil into the housing and press it tightly with the tooling. Performed in Vietnam Conduct detection after the coil is inserted into the housing. Performed in Vietnam Install the module and diode. Chinese Origin UF569 Housing Module, incorporated into Ignition Coil in Vietnam Weld the module and the wires together. Performed in Vietnam Energy test of semi-finished products - Test the energy of the semi-finished ignition coil using the performance test bench. Performed in Vietnam Preheat the product. Performed in Vietnam The product is filled with glue inside. Performed in Vietnam Curing of epoxy resin adhesive. Performed in Vietnam Load the rubber components. Origin China, incorporated into Ignition Coil in Vietnam Open-circuit test. Performed in Vietnam Performance test of the ignition coil. Performed in Vietnam Label and package. Performed in Vietnam 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). With the facts and documentation presented, it is the opinion of this office that the raw components used in the manufacturing of the Ignition Coil, part # UF569, is substantial, and substantially transforms the components into a finished product during the manufacturing process in Vietnam. Thus, it is the opinion of this office that the country of origin of the completed Ignition Coil 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