The country of origin of an oven spark plug assembly from China

N350058 July 8, 2025 OT:RR:NC:N4:410 CATEGORY: Origin Long Chen Thai Jiuzhou Electron Co Ltd 88/152 Moo 15 Bangsaotong Sub-District Bangsaotong 10540 Thailand RE: The country of origin of an oven spark plug assembly from China Dear Mr. Chen: In your letter dated June 11, 2025, you requested a country of origin ruling on an oven spark plug assembly. The provided images in the Bill of Materials indicate that the oven spark plug assembly consists of four “spark plugs” of similar construction but identified with different length and color bundled together. Each oven spark plug consists of a connector, terminal, and “ceramic” attached to an electric wire. The oven spark plug assembly is used in a gas range with a burner and spark module to ignite the gas. All the components are of Chinese origin and assembled into the finished oven spark plug assembly in Thailand. The assembly process in Thailand is described as follows: Assembling the electric wire and the terminal Gluing the ceramic Cutting the ignition head Polishing Test and package When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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 order to determine whether a substantial transformation occurs when components are assembled into completed products, all factors such as the components used to create the product and manufacturing processes that these components undergo are considered in order to determine whether a product with a new name, character, and use has been produced. No one factor is decisive, and assembly/manufacturing operations that are minimal will generally not result in a substantial transformation. In regard to the country of origin of the subject oven spark plug assembly, all the components of the oven spark plug assembly are of Chinese origin. The components are imported into Thailand where they are assembled into the finished product. The components do not undergo a physical change, nor do they change in character as a result of the assembly operations in Thailand. The components have a pre-determined end-use as parts and components of the oven spark plug assembly at the time of importation into Thailand and do not undergo a change in use due to assembly process in Thailand. Accordingly, the nature of the assembly process for the oven spark plug assembly, e.g., pressing, gluing, cutting, and polishing, in Thailand is not sufficiently complex or meaningful as to constitute a substantial transformation. The manufacturing process in Thailand does not create a new and different article of commerce with a distinct character and use that is not inherent in the components imported into Thailand. Therefore, the country of origin for this oven spark plug assembly will be China. 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 Michael Chen at michael.w.chen@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division