The country of origin of a window regulator

N353921 October 16, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Didie Muller Trade Pacific PLLC 700 Pennsylvania Avenue SE Washington, DC 20003 RE: The country of origin of a window regulator Dear Ms. Muller: In your letter dated September 18, 2025, you requested a country of origin ruling on window regulator, which you filed on behalf of Han Yale Vietnam Industrial Co., Ltd. The merchandise under consideration is a window regulator without a motor (Part Number 6610-0430), which is a mechanical component in automotive power window systems. This assembly is designed to guide and control the vertical movement of the vehicle window glass and is typically installed inside the door panel. While it does not include a motor, the regulator operates in conjunction with an electric motor to enable the automated raising and lowering of windows. The complete assembly consists of several integrated subassemblies, including the main and sub guide rail assemblies, slider assemblies (main and sub), cable assemblies (upper, lower, and sub), and various fastening and support components. Together, these components form the structural and mechanical system are required to support and control the window’s movement when powered by an external motor. According to the bill of materials (BOM) supplied with your request, sheets of galvanized steel purchased in Vietnam are further processed in Vietnam into the guide rail, guide rail brackets, cable drum cover, motor bracket, window clip, and tooth lock nut to create the main and sub guide rail assembly. In addition, other components for the slider assembly (main and sub) and cable assembly (upper, lower, and sub) are sourced from Taiwan and Vietnam and integrated into the said subassemblies in Vietnam. The final assembly of all subassemblies occur in Vietnam. You state that the production of the window regulator is conducted in two primary phases in Vietnam. The first phase involves stamping the galvanized and cold-rolled steel sheets into the finished guide rail, guide rail brackets, cable drum cover, motor bracket, window clip, and tooth lock nut. The second phase involves the integration of the stamped and purchased components into the subassemblies and then into the final unit. After that, the product is packaged for importation into the United States. 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). In the instant case, the main components of the window regulator are produced in Vietnam. The guide rail assemblies, slider components, and cable components are mainly made in Vietnam. Furthermore, the final assembly of the components into subassemblies, and then into the finished product is done in Vietnam. As a result, the country of origin of the window regulator will be Vietnam. 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 Liana Alvarez at liana.alvarez@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division