The country of origin of pressure sensors

N349940 July 2, 2025 OT:RR:NC:N1:105 CATEGORY: Origin JiHui Yao Hong Kong Sensorall International Limited Unit B-D, 16/F, Yardley Commercial Building 3 Connaught Road, West Sheung Wan Hong Kong China RE: The country of origin of pressure sensors Dear Ms. Yao: In your letter dated June 8, 2025, you requested a country of origin ruling on pressure sensors. The first item under consideration is the SA87A pressure sensor. The SA87A sensor consists of gold-plated electrical terminals, O-rings, a stainless steel or nickel alloy isolation diaphragm, a silicone pressure die, glass substrate, and a stainless-steel or nickel alloy body. In operation, pressure is applied to the metal isolation diaphragm. The addition of oil transfers pressure to the pressure die, which deflects under pressure causing electrical resistance changes in strain gauges. The Wheatstone bridge, an electrical circuit used to precisely measure unknown resistances by balancing two voltage divider networks, is formed by the strain gauges giving a voltage output in response to the resistance changes, thus establishing a relationship of voltage output versus pressure. The strain gauge signal is detected through the electrical terminals which are fused to the body with glass insulation. The signal can be used as is, normalized by additional external resistors, or additional circuits can be added for amplified output. The second item under consideration is the SAGF100 pressure sensor. The SAGF100 pressure sensor consists of silicon strain gauges, a stainless-steel header with electrical terminals, a wire bond printed circuit board (PCB), a strain gauge bonding agent, and a pressure port with integrated diaphragm. In operation, pressure is applied to the metal diaphragm through the pressure port. Strain gauges deflect together with the diaphragm causing electrical resistance changes in the strain gauges. The Wheatstone bridge is then formed by the strain gauges giving a voltage output in response to the resistance changes, establishing a relationship of voltage versus pressure. Next, the strain gauge signal is detected through the electrical terminals. Similar to the first sensor, the signal can be used as is, normalized by additional external resistors, or additional circuits can be added for amplified output. In your letter, you identify two manufacturing scenarios for each sensor. For the SA87A pressure sensor, materials are gathered from China, Japan, and the United States. The Chinese components include the cable assembly, PVC retaining nut, epoxy resin, housing, PCBA, O-ring, gilled gel silicone, connecting flexible printed circuit (FPC), sealing ball, header, gold wire, and diaphragm. The oil is from Japan while the silicone and die are produced in the United States. In the first scenario for the SA87A pressure sensor, the process begins in the United States with the creation of the wafers. The MEMS pressure sensor die is attached to the header that includes the strain gauges, membrane, and supporting structure. The next step includes wire bonding the MEMS pressure sensor die to the pins in the header. This is followed by wafer dicing to break the wafer into individual pressure dies. The manufacturing process then shifts to China where a worker glues the die to the glass using room temperature vulcanizing (RTV), a liquid silicone compound that cures at room temperature into a flexible rubber and is commonly used as an adhesive. Next, the worker wire bonds the die terminals and welds the isolation diaphragm to the body. The worker then fills silicone oil around the pressure die and seals the fill hole. This is followed by pressure tests, final assembly of the cable and connector, placement of the label, and packing. In the second scenario for the SA87A pressure sensor, the process begins the same way as scenario one. The MEMS pressure sensor die is attached to the header that includes the strain gauges, membrane, and supporting structure. The next step includes wire bonding the MEMS pressure sensor die to the pins in the header. This is followed by wafer dicing to break the wafer into individual pressure dies. In this scenario, the manufacturing process then shifts to Malaysia where a worker glues the die to the glass using RTV. Next, the worker wire bonds the die terminals and welds the isolation diaphragm to the body. The worker then fills silicone oil around the pressure die and seals the fill hole. This is followed by pressure tests, final assembly of the cable and connector, placement of the label, and packing. For the SAGF100 pressure sensor, materials are gathered from China, Japan, Germany, and the United States. The Chinese components include the flexible PCB, header, socket, ceramic bonding PCB, support, and pressure port. Resistors, solder, and solder paste are sourced from Japan, while the strain gauge is from Germany and the glass is from the United States. In the first scenario for the SAGF100 pressure sensor, the process begins in Germany with German-made wafers containing many strain gauges and supporting structures. The next step includes the wafer dicing to break the wafer into individual strain gauge dies. This is followed by bonding the strain gauge dies onto the diaphragm using adhesive. The manufacturing process then shifts to China where a worker attaches the wire bond PCB to the pressure port using RTV. Next, the wire bond strain gauges are connected to the wire bond PCB. The worker then solders wires or flex PCB from the wire bond PCB to the electrical terminals and welds the header to the pressure port. This is followed by pressure tests, final assembly of the cable and connector, placement of the label, and packing. In the second scenario for the SAGF100 pressure sensor, the process begins in Germany with German-made wafers containing many strain gauges and supporting structures. The next step includes the wafer dicing to break the wafer into individual strain gauge dies. The manufacturing process then shifts to Malaysia where the worker bonds the strain gauge dies onto the diaphragm using adhesive. Next, the worker attaches the wire bond PCB to the pressure port using RTV. The wire bond strain gauges are then connected to the wire bond PCB. The worker then solders wires or flex PCB from the wire bond PCB to the electrical terminals and welds the header to the pressure port. This is followed by pressure tests, final assembly of the cable and connector, placement of the label, and packing. 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). For the SA87A pressure sensor, it is the opinion of this office that the wafer of United States origin is the essential component of the finished good in both scenarios. The assembly operations conducted in China or Malaysia do not substantially transform the wafer as a result of encapsulating, soldering, gluing, and welding the wafer with additional components. The wafer is a pressure sensing device when it leaves the United States and can only be used as a pressure sensing device when the manufacturing process in China or Malaysia is complete. The assembly work, as described, is not complex so as to produce a new and different article. Therefore, the country of origin of the SA87A pressure sensor in both scenarios is the United States. For the SAGF100 pressure sensor, it is the opinion of this office that the German wafer is the essential component of the finished good in both scenarios. Similar to the results of the SA87A pressure sensor, the assembly operations conducted in China or Malaysia do not substantially transform the wafer as a result of encapsulating, soldering, gluing, and welding the wafer with additional components. Therefore, the country of origin of the second pressure sensor in both scenarios is Germany. 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) James Forkan Acting Director National Commodity Specialist Division