The country of origin of a fuel pump assembly

N349662 June 27, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Jiang Fan Zoren Automotive Electric (Thailand) Co., Ltd. 7/34 Moo 4, Phananikom Nikom Phatthana 21180 Thailand RE: The country of origin of a fuel pump assembly Dear Mr. Fan: In your letter dated May 31, 2025, you requested a country of origin ruling on behalf of Carter Fuel Systems. Descriptive information was provided with your submission. The fuel pump assembly is primarily comprised of a top cover and a bottom shell that encases an electric pump and an oil assembly. The fuel pump assembly, which is designed to be used in passenger vehicles, transports fuel from the fuel tank to the carburetor or fuel injectors. With respect to origin, the final assembly of the fuel pump occurs in Thailand and consists of components sourced from Thailand and China. Prior to the final assembly of the pump, the rotor used in the fuel pump is produced in Thailand. This process begins by pressing a shaft from China into an iron core from China. The iron core is subsequently pressed into a sheath. Next, insulation paper is inserted into the armature, and the armature is then pressed into a Chinese sourced commutator. Afterwards, processes such as winding, welding, and turning, are completed. Once the turning process is complete, the commutator is run through a slot, and spot welding is performed as deemed necessary. Throughout the steps, inspections and testing are completed. The fuel pump is also assembled in Thailand and commences with the assembly of a check valve using a riveting process. Once assembled, the valve is installed into the oil outlet nozzle of a Thai produced pump head. Afterwards, a wire end brush is inserted at the hook, allowing the positive and negative inserts to be welded in place. The resulting assembly, along with a carbon brush spring from Thailand, are inserted into a carbon brush holder and press-fit in place. Next, the pump head assembly is pressed onto the carbon brush holder, a stator assembly is pressed into the pump head, and a rotor assembly is pressed into the bottom casing of the pump. Afterwards, a Chinese produced impeller, along with lower and upper pump assemblies, which are sourced from Thailand, are inserted into the bottom casing, pressed into position and edge sealed. Inspections and testing are completed throughout the steps. The final assembly of the pump assembly begins by installing an O-ring and a socket into a top cover socket. Once the top cover is sealed, a valve assembly is pressed into the top cover and a steel ball and filter screen are pressed into a back cover. Bellows sourced from China are then pressed into the pump cover nozzle and pneumatically clamped in place. Next, the rear cover of a pump bracket is pressed into the oil inlet of the pump, and a pump holder is installed into the head of a fuel pump, which is then pressed onto the pump bracket. Subsequently, three guide rods are installed into the holes of a top cover, and three support springs are pressed into the top cover holes. Bellows sourced from China are then pressed into the top cover nozzle and pneumatically clamped in place. Afterwards, a diaphragm, which functions as the bottom shell, is aligned with an oil storage barrel. Then, an antivibration foot pad, a filter from China, and an oil level sensor assembly are installed. Next, a top cover connected to a pump, is installed into the oil storage barrel and clamped in place. The floater arm is then placed in the oil level sensor assembly, and a wiring harness is arranged and connected. Finally, a pressure sensor sourced from China is installed into its respective area of the top cover. Throughout the processes, the pump assembly undergoes various inspections and testing. 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). CBP has held that whether an assembly process is sufficiently complex to rise to the level of a substantial transformation is determined upon consideration of all the operations that occur within that country. Here, components from Thailand and China are assembled together in Thailand to produce subcomponents, which are then combined with other components in Thailand to form a fuel pump, and subsequently, a fuel pump assembly. 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 assembly 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, (for) Steven A. Mack Director National Commodity Specialist Division