The country of origin of ABS Sensors

N353655 September 30, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Kerry Wang Braumiller Law Group PLLC 5220 Spring Valley Road, Suite 200 Dallas, TX 75254 RE: The country of origin of ABS Sensors Dear Ms. Wang: In your letter dated September 11, 2025, you requested a country of origin ruling on behalf of your client, Eray Company, Ltd. There are two items at issue with this request. The first is identified by SKU number LG105051 and described as an active ABS sensor. The subject sensor is comprised of a Hall Effect Integrated Circuit (IC) sensor assembly attached to the end of a length of insulated cable. The subject device is attached within the wheel of a vehicle in order to detect the speed of the wheel. The Hall Effect sensor creates a magnetic field around the target wheel and senses when the wheel rotates and passes through the field. An electrical signal is then sent through the attached cable to the vehicle’s Electronic Control Unit (ECU) for interpretation of the wheel’s speed and rotation. In your request, you state that the assembly process is completed in Thailand. This process begins with the importation of Chinese-origin insulated cable as well as the Hall Effect IC. In Thailand, the cable is cut to length, and the ends are exposed for the addition of the sensor head and the connectors. The IC is then bent and installed within the molded sensor housing before this is attached to the end of the cable. A connector is then assembled onto the other end of the cable before the finished device is tested and packaged for shipment to the United States. The second item is identified by SKU number LG201281 and described as a passive ABS sensor. This sensor is comprised of a two-wire magnet sensor, which consists of a magnet within a coil of copper wire within a plastic enclosure. This sensor assembly is attached to an insulated cable conductor. You state that the device is attached within the wheel of a vehicle in order to detect the speed of the wheel. This function is achieved by the device creating a magnetic field around the target wheel. As the wheel rotates, the magnetic field is broken and an electrical impulse is sent to the ECU for interpretation. In your request, you state that the assembly process is also completed in Thailand. Insulated cable, which originates in China, is cut to the desired length and the ends are prepared for the addition of the sensor and connector. Copper wire, which also originates from China, is wrapped around a Chinese magnet and installed within the molded sensor head. The sensor assembly is then attached to the end of the cable and a connector is assembled onto the other end. 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 origin of both ABS sensors, you state that the processes performed in Thailand substantially transform the individual Chinese components. We disagree. In our view, the Hall Effect IC and magnetic sensor assembly impart the character of the finished devices as they embody the essential functional component of the device. Further, the Chinese conductor cable is also a critical component of the finished devices. Based on the totality of the facts, the processes performed in Thailand are simple in nature and do not transform the sensor and other electrical components into new and different articles of commerce. Accordingly, the country of origin for the Active ABS Sensor, SKU # LG105051, and the Passive ABS Sensor, SKU # LG201281, 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 Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division