The country of origin of a temperature and pressure sensor

N349893 June 18, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Christine Cai Aborn Automotive Sensor (Thailand) Co., Ltd. 890/26 moo. 3 Khao Khan Song, Subdistrict, Si Racha District, Chonburi Province 20110 Thailand RE: The country of origin of a temperature and pressure sensor Dear Ms. Cai: In your letter dated June 6, 2025, you requested a country of origin ruling on a temperature and pressure sensor. Descriptive literature was provided for our review. The item under consideration is described as an automotive temperature and manifold absolute pressure (MAP) sensor (model number 20070046). The sensor measures the temperature in the engine as well as the pressure within the engine’s intake manifold, which in turn provides information to the engine control unit (ECU) for optimal fuel delivery and ignition timing. In operation, the sensor measures the absolute pressure within the intake manifold, which is the pressure of the air entering the engine cylinders. This pressure information is then sent to the ECU as a voltage or frequency signal. The ECU uses the signal to determine the appropriate amount of fuel to inject and the correct ignition timing for optimal engine performance. The automotive temperature and MAP sensor includes a Chinese origin sensor head frame, which is the physical housing that encases the sensing components of the sensor, provides protection, and allows for the mounting of the various components. The pins, which serve as the essential connection points that enable both electrical and mechanical connections are also housed within the frame. The components from Thailand include the thermistor, printed circuit board assembly, glue, cover and O-ring. The manufacturing process begins in Thailand with the creation of the printed circuit board assembly using surface mount technology. Next, the thermistor is soldered to the board and the terminal is added. Then, the Chinese produced sensor head frame and other Thailand produced injection molded components are hot melted around the circuit board. The semi-finished product is then tested before the cover is glued into place. The O-rings are then added before the final performance testing, appearance inspection, and laser batching. Finally, the finished sensors are packaged for final shipment. When determining the country of origin, 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 regard to the country of origin of the automotive temperature sensors, it is our opinion the Chinese sensor head frame is transformed in Thailand from an article of plastic to a complete automotive temperature and MAP sensor. The creation of the PCBA in Thailand using surface mount technology, along with the addition of the thermistor and other Thailand origin components transforms the Chinese sensor head frame into a new product having a distinctive name, character, and use. Therefore, in our opinion, the country of origin of the automotive temperature and MAP sensor is Thailand, which is where the majority of the components are manufactured, including the PCBA and thermistor, and the assembly process is performed. 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