The country of origin of a motorized oven latch module

N357181 January 9, 2026 OT:RR:NC:N4:410 CATEGORY: Origin Jason Lin HTI Technology and Industries LLC 305 Tech Park Drive, Suite 109 La Vergne, TN 37086 RE: The country of origin of a motorized oven latch module Dear Mr. Lin: In your letter dated December 18, 2025, you requested a country of origin ruling on an oven front mount latch for the purposes of trade remedies. The product under consideration is a motorized oven latch module that connects to a metal rod which actuates a locking mechanism in a self-cleaning oven to keep the door securely locked during the high temperature cleaning cycle. The module consists of a synchronous gear motor, two motor rivets, two switch rivets, a mounting bracket, and a microswitch. Depending on the configuration, the assembly may include up to three microswitches. You explain that the synchronous gear motor used in this motorized oven latch module is an AC impedance-protected gear motor rated below 6 amps. It features a permanent magnet rotor. The bent tabs on the motor housing and gear plate function as magnetic poles. A copper coil wound around a bobbin is connected to the line voltage through lead wires or quick-connect terminals. The synchronous gear motor is made in Vietnam, and the balance of the components are made in China. The synchronous gear motor will be shipped to China to combine with the Chinese-originating components to produce the finished motorized oven latch module thought the following procedures: 1. Swage switch. 2. Swage motor. 3. Performance test. 4. Test and packaging. 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 order to determine whether a substantial transformation occurs when components are assembled into completed products, all factors such as the components used to create the product and manufacturing processes that these components undergo are considered in order to determine whether a product with a new name, character, and use has been produced. No one factor is decisive, and assembly/manufacturing operations that are minimal will generally not result in a substantial transformation. This office is of the opinion that the synchronous gear motor holds the basic nature of the finished motorized oven latch. Further, we find that the manufacturing process performed in China would be considered simple assembly and that the synchronous gear motor does not become a new article having a new name, character, or use. The origin of the finished component will remain the same as the origin of the synchronous gear motor as a substantial transformation does not occur in China. Accordingly, the country of origin for this motorized oven latch 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 CBP Regulations (19 CFR 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 Michael Chen at michael.w.chen@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division