The country-of-origin of a valve covers and components for an automotive engine

N356338 December 15, 2025 OT:RR:NC:N2:201 CATEGORY: Origin Drew Zhou XINTIAN Auto Parts LLC 1417 Greenfield Ave Arcadia California Arcadia, CA 91006 RE: The country-of-origin of a valve covers and components for an automotive engine Dear Mr. Zhou: In your letter dated November 21, 2025, you requested a country of origin ruling on a valve cover gasket with components. In your request, you state that the valve covers and components are assembled in Thailand. The raw materials are either of Chinese or Thai origin. A Bill of Materials (BOM) was submitted, along with the valve cover production process and other documents, illustrations, and videos showing the production work done in Thailand. The valve cover gasket is a critical engine component that secures and protects the cylinder head from external and internal elements. It also prevents oil from escaping the chamber and serves as a two-way shield, forming a tight fit between the engine and its cover. It is responsible for sealing off spark plug ports to prevent fluid leaks in the ignition system. According to the production video and illustrations, the following production processes take place in Thailand. Injection molding process Hot-insert copper nut process Vibration friction welding Assembly process-install caps Assembly process-install the gaskets Assembly process-install the nuts Air leakage test Final inspection Laser inscription 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 valve cover 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division