The country of origin of an intake manifold and a carbon canister

N351506 August 18, 2025 OT:RR:NC:N2:201 CATEGORY: Origin Drew Zhou Xintian Autoparts LLC 1417 Greenfield Ave. Arcadia, CA 91006 RE: The country of origin of an intake manifold and a carbon canister Dear Mr. Zhou: In your letter dated July 21, 2025, on behalf of your client, Dorman Products, Inc., located in Colmar, Pennsylvania, you requested a country-of-origin ruling determination for an intake manifold and a carbon canister assembled in Thailand with Chinese and Thai parts. You provided videos and documents showing the manufacturing process, and a bill of materials showing the country of origin of each component and part. The first item is an intake manifold, also known as the inlet manifold, which distributes air to the engine’s cylinders. On many modern cars the inlet manifold is also equipped with the fuel injectors. On older cars without fuel injections, or with throttle body injection, the manifold takes in the fuel-air mixture from the carburetor/throttle body to the cylinder heads. The manifold lets air into the combustion chamber on the intake stroke, which is then mixed with fuel from the injector. The air reaches the manifold through the air cleaner assembly, which contains the car's air filter. This air filter is designed to stop dust and other foreign bodies from entering the intake and damaging the engine. You state that the intake manifold, which is the subject of this request, is made of plastic, polyamide 6 with 35% glass fiber reinforcement, commonly referred to as PA6 GF35. The following intake manifold production process which you provided video substantiation of takes place in Thailand: 1. Injection molding process 2. Hot-insert copper nut process 3. Vibration friction welding 4. Air leakage test 5. Chip removing The second item has been identified as an activated carbon canister. The activated carbon canister is used to capture hydrocarbon vapor emissions from the fuel tank as part of a motor vehicle’s evaporative emission control system (EVAP). When the engine is running these stored hydrocarbons can be purged by the vehicle’s opening of a valve to the intake system and reversing the flow through the carbon canister allowing the engine to consume the hydrocarbon vapors by combustion. You state that the carbon canister is made of plastic (nylon) and polyamide 6 with 35% glass fiber reinforcement, commonly referred to as PA6 GF35, with activated carbon powder material. The following production processes, which you provided video substantiation of, takes place in Thailand: 1. Injection molding process 2. Vibration friction welding 3. Ultrasonic welding 4. Load activated carbon 5. Vibration friction welding 6. Pressure resistance test 7. Air leakage test 8. Final inspection 9. Laser inscription 10. Packing When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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). With the facts and documentation presented, it is the opinion of this office that the manufacturing operations of the intake manifold and a carbon canister are substantial and meaningful, and the individual components are substantially transformed into a finished product during the manufacturing process in Thailand. Thus, it is the opinion of this office that the country of origin of the completed articles is 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 Matthew Sullivan at matthew.sullivan@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division