The country of origin of an air temperature sensor

N350320 July 7, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Jason Kenner Sandler, Travis & Rosenberg, P.A. 675 Third Avenue, Suite 2425 New York, NY 10017 RE: The country of origin of an air temperature sensor Dear Mr. Kenner: In your letter dated June 17, 2025, on behalf of your client, Panasonic Industry Company, Ltd., you requested a country of origin ruling on an Air Temperature Sensor. Descriptive literature was provided for our review. The item under consideration is described as an Intake Air Temperature Sensor (model number ERTSA18D202U), which is attached to the intake pipe inside an automobile’s engine bay. Depending on the temperature of the air taken into the engine, the resistance within the sensor changes. This change in resistance is transmitted to and detected by the automobile and used for engine control. The Air Temperature Sensor is comprised of numerous components from Japan and China. The Japanese components include the thermistor (sensor that converts temperature to a specific resistance value), lead wires (connect the thermistors to the terminals), terminals (connect the thermistor’s electrical output to the automobile) and resin for the manufacture of the cap and molded parts. The Chinese components include an O-ring (provides the sensor with an air seal), collar (brass component which affixes the Air Temperature Sensor to the automobile), tube (provides insulation between the lead wires), cap (plastic component that protects the thermistor made from Japanese resin) and additional molded parts (maintain air tightness of the finished sensor and also made with Japanese resin). The Thermistor chip is manufactured in Japan through a multi-step ceramic materials process. The materials for the thermistor chip are ceramic materials, primarily oxide semiconductor powders (such as manganese, nickel, cobalt, etc.). These powders are mixed and homogenized. The mixed materials are then molded through press molding and sintered at high temperatures to enhance the strength and electrical properties of the ceramics. Conductive metal electrodes (gold) are then formed at both ends of the thermistor. If necessary, the surface of the thermistor element is sliced. Finally, after attaching lead wires to the thermistor chip with paste, the finished thermistor chip is encapsulated in a glass tube by adding heat. In China, the fully finished thermistor chip with lead wires is connected to terminals via a welding process. Molded plastic parts are created through injection molding which are then combined with the finished thermistor with lead wires and terminals through insert molding to create a finished Air Temperature Sensor. The finished sensor is then inspected for air leaks and appearance and packaged. 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). Regarding the origin of the Air Temperature Sensor, it is our opinion that the addition of the Chinese O-ring, collar, tube, cap, and molded parts do not substantially transform the completed Japanese thermistor, which provides the sensor the ability to measure temperature. The thermistor chip can only be used with the Air Temperature Sensor when it leaves Japan and is predominately encapsulated in plastic for air sealing and protection purposes. The thermistor chip does not turn into a new product with a distinctive name, character, and use. Therefore, in our opinion, the country of origin of the Intake Air Temperature Sensor (model number ERTSA18D202U) is Japan, which is where the thermistor chip is completed. 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