The country of origin of door strikes for front-loading dryers

N350724 July 16, 2025 OT:RR:NC:N1:104 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 door strikes for front-loading dryers Dear Mr. Chen: In your letter dated June 27, 2025, you requested a country of origin ruling. The products in question are door strikes (a.k.a. door latch strikes), model numbers 308D1124P003 (white) and 308D1124P004 (gray). These plastic components are used in a front-loading drying machine’s door lock system. The door strike is secured to the front of the drying machine’s frame with tabs and fasteners, and acts as a mating part for the machine’s door latch on the dryer door, securing the door in the closed position. The door strikes will be produced in two countries, China and Thailand. Chinese-origin PA66 plastic resin pellets are sent to Thailand where they are dehumidified and then placed into a plastic injection molding machine. The injection molding machine fully forms the complete door strike. The product is then tested and packaged in Thailand. You indicate that the plastic resin pellets account for 40% of the finished part’s total cost, while the operations in Thailand account for the remaining 60%. 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 this case, the injection molding of the Chinese resin pellets in Thailand substantially transforms the pellets into door strikes of Thai origin. As such, the country of origin of the door strikes, model numbers 308D1124P003 and 308D1124P004, will be Thailand. 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 Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division