The country of origin of ignition coils for an automotive engine

N348147 May 22, 2025 OT:RR:NC:N2:201 CATEGORY: Origin Wally Yu HBL LTD. 88/50-51. Moo 8 Tha Kham Sub-District Bang Pakong District Chachoengsao Province Bangkok, Thailand RE: The country of origin of ignition coils for an automotive engine Dear Mr. Yu: In your letter dated April 23, 2025, you requested a country-of-origin ruling on ignition coils. In your request, you state that the ignition coils are fully produced and assembled in Thailand. The raw materials are either of Chinese or Thai origin. You presented documents and a video showing the production work done in Thailand. Ignition coils are a crucial component in a vehicle's ignition system. Its primary function is to convert the low voltage from the car's battery into the high voltage needed to create a spark in the spark plugs. This spark ignites the air-fuel mixture in the engine cylinders, enabling the engine to run. The first item under consideration has been identified as Ignition Coil, part # VB-N3001. You state that the procedure for producing Ignition Coil, part # VB-N3001 consists of the following steps: Main Housing- Protects internal components from physical shocks, vibrations, or external damage. Origin Thailand o Housing is manufactured in Thailand from raw materials sourced from China and Thailand. Primary Winding- Through principle of electromagnetic induction generates a strong magnetic field around iron core. Induces high voltage in secondary coil. Origin Thailand o Primary Winding is manufactured in Thailand from raw materials sourced from China and Thailand. Secondary Winding- Converts electrical energy generated by primary coil into high voltage. Origin Thailand o Secondary Winding is manufactured in Thailand from raw materials sourced from China and Thailand. Epoxy Resin- “Potted” inside of Main Housing to connect the various components of the ignition coil together to form a solid whole. The epoxy encapsulates all the internal components and isolates them from the outside contaminants and external forces. Origin China o Epoxy Resin is a product of China. It is heated to liquid form and “potted” into the housing in Thailand. The second item under consideration has been identified as an Ignition Coil, part # VB-5015A. You state that the procedure for producing Ignition Coil, part # VB-5015A consists of the following steps: Main Housing- Protects internal components from physical shocks, vibrations, or external damage. Origin Thailand o Housing is manufactured in Thailand from raw materials sourced from China and Thailand. Primary Winding- Through principle of electromagnetic induction generates a strong magnetic field around iron core. Induces high voltage in secondary coil. Origin Thailand o Primary Winding is manufactured in Thailand from raw materials sourced from China and Thailand. Secondary Winding- Converts electrical energy generated by primary coil into high voltage. Origin Thailand o Secondary Winding is manufactured in Thailand from raw materials sourced from China and Thailand. Primary Connector Assembly- Provides low-power power supply and controls the flow of current through the circuit breakers. Origin Thailand o Primary Connector Assembly is manufactured in Thailand from raw materials and components from Thailand and China. Epoxy Resin- “Potted” inside of Main Housing to connect the various components of the ignition coil together to form a solid whole. The epoxy encapsulates all the internal components and isolates them from the outside contaminants and external forces. Origin China o Epoxy Resin is a product of China. It is heated to liquid form and “potted” into the housing in Thailand. The third item under consideration has been identified as an Ignition Coil, part # VB-N8066A. You state that the procedure for producing Ignition Coil, part # VB-N8066A consists of the following steps: Main Housing- Protects internal components from physical shocks, vibrations, or external damage. Origin Thailand o Housing is manufactured in Thailand from raw materials sourced from China and Thailand. Primary Winding- Through principle of electromagnetic induction generates a strong magnetic field around iron core. Induces high voltage in secondary coil. Origin Thailand o Primary Winding is manufactured in Thailand from raw materials sourced from China and Thailand. Secondary Winding- Converts electrical energy generated by primary coil into high voltage. Origin Thailand o Secondary Winding is manufactured in Thailand from raw materials sourced from China and Thailand. Internal Magnetic Sleeve- Enhances and guides the magnetic field. Provides additional structural support and heat dissipation. Stabilizes induction parameters. Origin China o Internal Magnetic Sleeve is manufactured in China and incorporated into ignition coil in Thailand. External Magnetic Sleeve- Enhances and guides the magnetic field. Provides additional structural support and heat dissipation. Stabilizes induction parameters. Origin China o External Magnetic Sleeve is manufactured in China and incorporated into ignition coil in Thailand. Ignition Module- Receives signals from the Engine Control Unit (ECU) to accurately switch the primary winding on and off, triggering spark plugs at ideal moment to initiate combustion. Monitors primary circuit current and voltage to detect faults. Origin Thailand o Ignition Module is manufactured in Thailand from raw materials sourced in Thailand and China. Epoxy Resin- “Potted” inside of Main Housing to connect the various components of the ignition coil together to form a solid whole. The epoxy encapsulates all the internal components and isolates them from the outside contaminants and external forces. Origin China o Epoxy Resin is a product of China. It is heated to liquid form and “potted” into the housing in Thailand. The fourth item has been identified as an Ignition Coil, part # VB-A9005. You state that the procedure for producing Ignition Coil, part # VB-A9005, consists of the following steps: Main Housing- Protects internal components from physical shocks, vibrations, or external damage. Origin Thailand o Housing is manufactured in Thailand from raw materials sourced from China and Thailand. Primary Winding- Through principle of electromagnetic induction generates a strong magnetic field around iron core. Induces high voltage in secondary coil. Origin Thailand o Primary Winding is manufactured in Thailand from raw materials sourced from China and Thailand. Secondary Winding- Converts electrical energy generated by primary coil into high voltage. Origin Thailand o Secondary Winding is manufactured in Thailand from raw materials sourced from China and Thailand. Epoxy Resin- “Potted” inside of Main Housing to connect the various components of the ignition coil together to form a solid whole. The epoxy encapsulates all the internal components and isolates them from the outside contaminants and external forces. Origin China o Epoxy Resin is a product of China. It is heated to liquid form and “potted” into the housing in Thailand. The final item under consideration has been identified as an Ignition Coil, part # VB-N9592. You state that the procedure for producing Ignition Coil, part # VB-N9592 consists of the following steps: Main Housing- Protects internal components from physical shocks, vibrations, or external damage. Origin Thailand o Housing is manufactured in Thailand from raw materials sourced from China and Thailand. Primary Winding- Through principle of electromagnetic induction generates a strong magnetic field around iron core. Induces high voltage in secondary coil. Origin Thailand o Primary Winding is manufactured in Thailand from raw materials sourced from China and Thailand. Secondary Winding- Converts electrical energy generated by primary coil into high voltage. Origin Thailand o Secondary Winding is manufactured in Thailand from raw materials sourced from China and Thailand. Internal Magnetic Sleeve- Enhances and guides the magnetic field. Provides additional structural support and heat dissipation. Stabilizes induction parameters. Origin China o Internal Magnetic Sleeve is manufactured in China and incorporated into ignition coil in Thailand. External Magnetic Sleeve- Enhances and guides the magnetic field. Provides additional structural support and heat dissipation. Stabilizes induction parameters. Origin China o External Magnetic Sleeve is manufactured in China and incorporated into ignition coil in Thailand. Epoxy Resin- “Potted” inside of Main Housing to connect the various components of the ignition coil together to form a solid whole. The epoxy encapsulates all the internal components and isolates them from the outside contaminants and external forces. Origin China o Epoxy Resin is a product of China. It is heated to liquid form and “potted” into the housing 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 (“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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. With the facts and documentation presented, it is the opinion of this office that the Ignition Coil’s components and subassemblies are substantially transformed during the manufacturing process in Thailand. Thus, the country of origin of the complete automotive engine Ignition Coil is Thailand for marking purposes. As the country of origin of the subject item is Thailand, the Section 301 Trade Remedy duties are not applicable to the Ignition Coil under consideration. Thailand has been determined as the country in which the product was produced, therefore the Ignition Coil may be marked “Made in 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 Matthew Sullivan at matthew.sullivan@cbp.dhs.gov. Sincerely, (for) Steven A. Mack Director National Commodity Specialist Division