The country of origin of an electric-powered injection molding machine.

N349312 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 an electric-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 E-MAC 265/110 series (E-MAC) is a customizable electric-powered injection molding machine designed to mass produce high-quality 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 E-MAC. The complete E-MAC is comprised of four principal units: injection unit, clamping unit, frame, and electronics. The injection unit consists of: (1) the 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) belts and pulleys to transmit rotational motion from the motor to other mechanical components; (5) ball screw, which converts rotary motion into linear motion; (6) rails and slides to guide the moving part of the injection unit; (7) bearings, fittings and gauges; and (8) miscellaneous auxiliary electrical, mechanical and other parts for assembly, functionality and maintenance. The clamping unit consists of the base platen, moving platen, fixed platen, tie bar system, a servo motor, ball screw, rails and slides, bearings, belts and pulleys, and other auxiliary components. The frame is the structural foundation, with both the clamping unit and the injection unit mounted thereon. Finally, the electronics include the controller, servo drive, wiring components, electric components, cable harnesses, transformers, resistors, fuses and miscellaneous items. Engel manufactures the E-MAC at its facility in Mexico, utilizing approximately 1,100 components are sourced from China, the EU, and Mexico. You state that 26% of the E-MAC’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 base platen, moving platen, fixed platen, tie bars, and the basic injection unit skeleton. In addition, advanced electronics, servo motors, ball screws, and other key components sourced from EU countries, including those for the key plasticizing unit, are shipped from the EU to Mexico to be assembled with the Chinese cast components. The EU components account for approximately 50% of the total value of 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 function injection molding machine. You state that the Mexican production process spans about four to six weeks and is organized into approximately 10 distinct sub-assemblies, each involving individual component parts assembled in Mexico. 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 E-MAC 265/110 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