The country of origin of a hydraulically-powered injection molding machine.

N349311 June 12, 2025 OT:RR:NC:N1:104 CATEGORY: Origin Nithya Nagarajan Husch Blackwell LLP 1801 Pennsylvania Avenue, NW Suite 1000 Washington, DC 20006 RE: The country of origin of a hydraulically-powered injection molding machine. Dear Ms. Nagarajan: In your letter dated May 21, 2025, on behalf of your client Engel Machinery Inc., you requested a country of origin ruling. The Engel T-WIN 11600/1460 series (T-WIN) is a hydraulically-powered, customizable injection molding machine designed to mass produce a wide range of medium to large-sized molded plastic products. Components from these units are manufactured in China, European Union (EU) countries, and Mexico. In your submission, you provided a description of the manufacturing process for the T-WIN. The complete T-WIN is comprised of four principal units: injection unit, clamping unit, frame, and electronics. The injection unit consists of: (1) a plasticizing unit, a key component made up of a barrel, worm screw, heater bands, and electrical connections, which melts raw plastic pellets and prepares the material for injection into the mold cavity; (2) the basic injection unit “skeleton” which is a metal part the motor is mounted on; (3) servo motors which regulate the entire operation of the clamping unit including plasticizing screw rotation within the barrel; (4) hydraulics for moving the screw to the melt and injecting the plastic material into the mold; (5) rails and slides to guide the moving part of the injection unit; and (6) miscellaneous auxiliary electrical, mechanical and other parts for assembly, functionality and maintenance. The clamping unit consists of the moving platen, fixed platen, hydraulic and pneumatic components, tie bar system, interlocks, a servo motor, a support assembly, sensors, thermometers, gauges, and miscellaneous auxiliary components. The frame is the structural foundation and is comprised of two parts, one for the clamping unit and the other of the injection unit. Finally, the electronics include the controller, servo drive, wiring components, electric components, cable harnesses, transformers, resistors, fuses and miscellaneous items. Engel manufactures the T-WIN at its facility in Mexico, utilizing approximately 1,700 components sourced from China, the EU, and Mexico. You state that 38% of the T-WIN’s total value is derived from Chinese-origin components, which in terms of value consist largely of four cast metal structural parts, i.e., the basic injection unit skeleton, fixed platen, movable platen, and tie bar system. In addition, several components sourced from EU countries, including those for the plasticizing unit and hydraulic systems, are shipped from the EU to Mexico to be assembled with the Chinese cast components. The EU components account for approximately 34% of the total value of the injection molding machine. Mexican components include certain mechanical components of the injection and clamping units, the frame, and cable harnesses. In Mexico, the EU components are assembled with the Chinese components and Mexican components. The assembly process in Mexico involves the integration of hundreds of components into units and the subsequent assembly of a fully functional injection molding machine. You state that the process spans four to six weeks and requires advanced expertise in electrical, mechanical, and software engineering. Lastly, Engel’s software engineers program the machine’s software, and the machine undergoes a rigorous quality control processes and mechanical and electrical testing. When determining the country of origin for purposes of applying current trade remedies under Section 301 and for other purposes, 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). Based on your description of the manufacturing and assembly operations, the nature of the processing performed in Mexico is not simple. These complex operations result in the individual component parts losing their separate identities to become a new article, i.e., a complete functioning injection molding machine. Therefore, the country of origin of the T-WIN 11600/1460 series injection molding machine will be Mexico. 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 Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, (for) Steven A. Mack Director National Commodity Specialist Division