The country of origin of a door latch for a front-loading dryer

N351460 July 29, 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 a door latch for a front-loading dryer Dear Mr. Chen: In your letter dated July 18, 2025, you requested a country of origin ruling. The product in question is a door latch, model number 308D1127P001, for a front-loading dryer. This article is used in the drying machine’s door lock system and is comprised of a specially shaped plastic housing, lever, and a metal spring. The door latch is secured to the dryer’s door, and acts as a mating part for the machine’s door strike on the drying machine, securing the door in the closed position. The door latch will be produced in two countries, China and Thailand, under two production scenarios. In scenario 1, Chinese-origin PA66 plastic resin pellets are sent to Thailand where they are dehumidified and then placed into a plastic injection molding machine to fully form the housing and lever components. In Thailand, the Chinese-origin spring is hand-attached to the lever and housing, and all three components are quickly pushed together using a manual table-top press, completing the article. In scenario 2, all three components (housing, lever, and spring) are of Chinese-origin and ready for assembly when they arrive in Thailand, where they are assembled using the same simple hand-placement and pressing operations described in scenario 1. 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). For scenario 1, the components that impart the essence of the door latch, i.e., the lever and housing, are produced through injection molding in Thailand. The formation of these components from raw Chinese resin pellets substantially transforms the pellets into components of Thai origin. As such, the country of origin of the door latch in scenario 1 will be Thailand. For scenario 2, the simple assembly operations in Thailand do not substantially transform the fully formed Chinese components. As such, the country of origin of the door latch in scenario 2 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 Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division