The country of origin of a pressure sensor

N353851 October 10, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Edward Hayes Leake and Andersson 1100 Poydras Street, Suite 1700 New Orleans, LA 70163 RE: The country of origin of a pressure sensor Dear Mr. Hayes: In your letter dated September 17, 2025, on behalf of your client, Bomtec (Thailand) Co., Ltd., you requested a country of origin ruling on a pressure sensor. Descriptive literature was provided for our review. The item under consideration is described as a high-pressure sensor (item number BH012A), which is a device used in the automotive, industrial, and medical fields to monitor pressure changes in various systems and feed data back to the control unit. The information allows for precise control, safety assurance, and emission optimization within an automobile. When pressure is applied to the chip component, the diaphragm undergoes slight deformation. It is then stretched or compressed, and its own resistance value changes accordingly. The Wheatstone bridge circuit connected to the diaphragm can amplify the tiny resistance change into an electrical signal proportional to the pressure for output. This signal is directly transmitted to the control system of the vehicle or equipment. The pressure sensor does not provide readings directly to the user and instead is a passive type of device that receives external physical changes and generates outputs to the engine control unit (ECU) or central processing unit (CPU) for judgment. In your letter, you state the entire manufacturing process will occur in Thailand. For the BH012A pressure sensor, materials are gathered separately from various countries including the United States, Thailand, China, Malaysia, South Korea, and Taiwan. The Chinese components consist of the printed circuit board (PCB), resistors, electric capacity, integrated chip, diode, elastomer kit, metal pin, stainless steel sleeve, and spring. The Thai components encompass an integrated chip, soldering paste, tape, boxes, and other packaging materials. Aluminum wire is sourced from Malaysia, an integrated chip from Taiwan, glue and plastic particle from Korea, and glue from the United States. The pressure sensor production process occurs entirely in Thailand. Incoming raw materials are inspected before moving on to the warehouse for sorting based on the production work order. Next, the raw materials transit to the injection molding stage for formation of the plastic housing. Plastic particles, metal pins, and a stainless-steel sleeve are placed into a vertical injection molding machine to become the insert core. The burr, or excess molded material that forms on a part’s edge or surface after the injection molding process, is manually removed by a worker. The PCB is then placed in an oven for baking, after which the integrated chip is placed in the programming machine where the product program is input by the programmer and written into the chip. After the software is written into the chip, the CPU acquires the ability to handle the application of pressure sensors and output signals. Afterward, the Surface Mount Technology (SMT) stage commences where electronic components are mounted onto the PCB to form the Printed Circuit Board Assembly (PCBA). A worker begins to prepare the soldering paste and as it is warming up, the assembly of the electronic material is prepared for placement. A worker then places the ceramic PCB into an electrostatic frame for loading onto the machine track. Next, soldering paste is manually added to the printing machine, followed by the solder paste inspection. The chip mounter then mounts electronic components to the PCB. A lead-free hot air reflow oven then welds the electronic components to the PCB. The PCB is unloaded from the electronic frame and then sent on to the laser cutting machine which is the last step before assembly and testing. During the assembly and testing stage, the components are assembled into a complete pressure sensor product and machine calibrated. Pressure calibration instruments are utilized to collect, calibrate, and calculate the intake pressure and temperature. After the tests are complete the finished pressure sensor is packaged for shipment to the United States. 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). Regarding the origin of the BH012A pressure sensor, it is our opinion that the manufacturing process performed in Thailand is considered complex and transforms the individual components from the United States, China, Malaysia, South Korea, and Taiwan into a new product having a distinctive name, character, and use. Notably, the creation of the PCBA in Thailand using surface mount technology, along with the programming, creates a functional pressure sensor from the separate components that lose their individual characteristics. Therefore, in our opinion, the country of origin of the BH012A pressure sensor is Thailand, which is where the majority of components are manufactured, including the programmed PCBA, and the assembly process is performed. 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division