The country of origin of a fuel pump

N348037 May 9, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Xiaozhen Qiao Joinhands Injection System (Thailand) Co., Ltd. 890 / 25 Moo 3 Khao Khan Song Subdistrict, Si Racha District Chonburi Province, Si Racha 20110 Thailand RE: The country of origin of a fuel pump Dear Ms. Qiao: In your letter dated April 21, 2025, you requested a country of origin ruling on a fuel pump. Descriptive information was provided with your submission. The fuel pump, part number JCMT-001, is composed of upper and lower bodies that encase a pump membrane subassembly, valves, and a variety of seals and gaskets. In use, the fuel pump transports fuel from the fuel tank to the engine’s combustion chamber. The aluminum fuel pump is designed to be used in motor vehicles equipped with carburetor engines or engines with low fuel pressure requirements. With respect to origin, the final assembly of the pump occurs in Thailand and consists of processes that combine a lower body produced in Thailand with components that are sourced in China. The final assembly process begins by pressing gaskets, pressure plates, and springs to each other to form the inlet and outlet valves. Afterwards, the inlet and outlet valves are installed into the upper iron shell. The fuel pipe and joint fuel cup are then placed on a fixture and welded onto the exterior of the upper shell. Next, the pump membrane components, which consist of a diaphragm, upper and lower pressure plates, an axis, a fuel tray, two springs, a fuel seal frame, various gaskets and seals, and a rocker arm with a shaft, are assembled to each other using a riveting machine. The resulting pump membrane subassembly is riveted into the lower body. Lastly, the upper and lower bodies are edge pressed using a riveting machine to complete the fuel pump. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, 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 are assembled together in Thailand to produce a pump membrane subassembly and valves which are then combined with other components, including an upper body from China and a lower body from Thailand, to form a fuel pump. When considering the totality of the circumstances, this office finds that the assembly processes that 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 processes described in the submission, we find the country of origin of the fuel pump 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