The country of origin of a digital stick thermometer

N349038 May 30, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Tirta Halim T Customs Broker, Inc. 5777 W. Century Blvd. #965 Los Angeles, CA 90045 RE: The country of origin of a digital stick thermometer Dear Mr. Halim: In your letter dated May 15, 2025, on behalf of your client, Fortunit Creative Co., Ltd., you requested a country of origin ruling on a digital stick thermometer. The item under consideration is described as a digital human body temperature thermometer (part number DMT-418), which is a digital stick thermometer that provides the temperature reading to the user via an integrated backlit LED screen. In operation, the user will place the thermometer in the mouth, rectum, or under the armpit and wait for the reading to display. When the temperature detected by the thermometer does not rise for 4 seconds, the sound is prompted, and the accurate temperature value is displayed. The DMT-418 is accurate to plus or minus 0.2 degrees Fahrenheit within a range of 90 degrees Fahrenheit to 109.9 degrees Fahrenheit. The thermometer is powered by a 1.5 V button battery, measures 13.9 cm by 2.3 cm by 1.2 cm, and weighs 12 grams. To manufacture the digital human body temperature thermometer components are gathered from China and Cambodia. The Chinese components include the MT movement, LCD screen, MT sheath, buzzer, conductive shrapnel, conductive bar, conductive point, Chip-on-Board (COB), sensor, battery and battery clamps. The Cambodian components include the label, giftbox, manual, inner box, carton box, enclosure, cover and dustproof case. The complete assembly is performed in Cambodia. In Cambodia, the process starts by placing the movement and the conductive points into the movement vibration plate. Next, the positive and negative battery clips are placed in the fixed area of the connecting tape. The battery is then placed on the drive belt in the battery area and the battery materials are prepared. During the automatic assembly process, the battery voltage of each assembled product is detected. After completing the material preparation and inspection work, the automated assembly production is completed. Next, tweezers are used to remove the protective film on the front of the LCD and check whether the LCD screen is damaged. Next, the COB and sensor are generated by using an automatic soldering machine. The user arranges the MT COBs neatly on the plate arrangement fixture distinguishing the front and back direction. After the arrangement is completed, the machine is started, and the automatic rotation cycle welding begins. The worker then places the MT18 movement, with the battery holder already installed, into the movement vibration plate. The liquid crystal film bubble shell tray is then placed along with the buzzer sheets. Next, the positive conductive string piece of the buzzer sheet, the conductive strip and the negative conductive spring piece of the buzzer sheet are placed. The welded COBs are then added to the belt and the automated hot-pressing step is completed. The thermometer is then inserted into the head of the sheath, ensuring the black end of the sensing wire can be inserted into the bottom of the steel sheath. The product is then left for 24 hours to dry. The completed thermometer is then ready for screen printing the customer’s information, final testing, and packaging. 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). In this instance, it is this office’s opinion that the Chinese-produced components provide the essence of the digital thermometer. The Chinese components, including the COB and sensor, are not substantially changed by the assembly operations performed in Cambodia, as these operations are not complex or meaningful enough and they do not render a new and different article. The Chinese-produced components contain the “enabling technology” that provides the essential operation elements for the digital stick thermometers to work. In view of these facts, the country of origin is China. 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) Steven A. Mack Director National Commodity Specialist Division