The country of origin of selector switches for washing machines

N350963 July 17, 2025 OT:RR:NC:N2:212 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 selector switches for washing machines Dear Mr. Chen: In your letter dated July 7, 2025, you requested a country of origin ruling on selector switches for washing machines. The merchandise under consideration is described as a selector switch for use in a washing machine and is identified by part numbers 290D2274G001 and 290D2275G001. It is noted that the different variations are virtually identical and only differ by the specific appliance with which they will be used. The subject device is comprised of a printed circuit board assembly (PCBA), upon which is a cam assembly, both enclosed within a plastic housing. Extending from the housing is a wire harness with a specialized connector at the end. In use, the subject selector switch is attached to a washing machine. The cam acts as a rotational switch allowing the user to select the speed and/or cycle for the machine. We note that the electrical contact and resistance selection is performed within the PCBA. In your request, you provide two production configurations. In the first configuration, you state the PCBA, cam assembly, plastic housing, connector and retainer are all manufactured in China. The Chinese components are then sent to Thailand where the cam is assembled with the plastic housing, the PCBA is added and multiple switches are assembled into one piece. The finished device is then tested and packaged for shipment to the United States. The second configuration provided states that the PCBA is manufactured in Thailand. The cam assembly, plastic housing, connector and retainer are all manufactured in China. The Chinese components are then sent to Thailand where the Chinese cam assembly is inserted into the Chinese housing and the PCBA from Thailand is added. Multiple switches are assembled into one piece in Thailand. The finished device is then 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). Regarding the subject of the selector switch, it is the opinion of this office that for configuration 1, the Chinese PCBA which is incorporated into the plastic housing and cam imparts the character of the finished device. Further, the assembly process performed in Thailand is simple in nature and does not substantially transform the PCBA or other Chinese components into new and different article of commerce. Based on the facts presented for configuration 1, the country of origin of the washing machine selector switch, part 290D2274G001 and 290D2275G001 will be China. Regarding configuration 2, it is the opinion of this office that the PCBA originating from Thailand, which is incorporated into the plastic housing and cam imparts the character of the finished device. Further, the assembly process performed in Thailand is simple in nature. Based on the facts presented for configuration 2, the country of origin of the washing machine selector switch, part 290D2274G001 and 290D2275G001 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 Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division