The country of origin and marking of photovoltaic junction boxes

N350562 July 9, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Ting Lin Acuitus PTE. LTD. 140 Upper Bukit Timah Road #03-05 Beauty World Plaza Singapore 588176 Singapore RE: The country of origin and marking of photovoltaic junction boxes Dear Mr. Lin: In your letter dated June 24, 2025, you requested a country of origin ruling. There are two items at issue with this request, which are each described as photovoltaic junction box assemblies, or jboxes. The first jbox is identified by part number PV-JB03D. The fist jbox is comprised of a plastic housing within which are electrical terminals and an optional semiconductor diode. Attached to the terminals are two insulated electrical conductors, one with a positive polarity and one with a negative polarity, that extend from the housing. At the end of each conductor are specific electrical connectors designed to be attached to a solar panel after importation. The second jbox is identified by part number PV-JB12x and is comprised of three plastic housings that contain electrical terminals and optional semiconductor diodes. Two insulated electrical wire harnesses extend from the housings, one with a positive polarity and one with a negative polarity. At each end of the harness are electrical connectors designed to be attached to a solar panel after importation. In use, both jbox assemblies function identically. The subject devices are specifically used as a subcomponent in solar panel assemblies in order to supply the generated electricity from the panel to the outside source. The diode, if present, acts to prevent the backflow of electricity into the panel that could create an electrical failure. In your request, you state that the assembly process for the subject jboxes is substantially similar. Insulated, complete wire harnesses are manufactured in Thailand or Malaysia and shipped on reels to China. In China, the cables are cut to length and the ends are stripped prior to the connectors being attached. The diodes are then placed into the plastic housings before the harnesses are welded onto the terminals within the housing. The housing is then closed and the completed device is tested and packaged for shipment to the United States. 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Based on the information provided, it is the opinion of this office that the insulated harnesses impart the character of the finished devices as they provide the principal electrical component. Further, the processes performed in China do not substantially transform the harnesses into new and different articles of commerce. The country of origin for marking and trade remedy purposes of the jbox assemblies, part numbers PV-JB03D and PV-JB12x, will be Malaysia or Thailand, where the harness originates. 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 Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, James Forkan Acting Director National Commodity Specialist Division