The country of origin of a magnetic coil assembly

N358555 February 20, 2026 OT:RR:NC:N1:103 CATEGORY: Origin David Robeson Mohawk Global Trade Advisors 123 Air Cargo Road North Syracuse, NY 13212 RE: The country of origin of a magnetic coil assembly Dear Mr. Robeson: In your letter dated February 4, 2026, you requested a country of origin ruling on behalf of your client, HTI Global Point. The merchandise under consideration is identified as a Magnetic Coil Assembly, part number 42405, which is used in a solenoid pump. The assembly consists of loops of electrical wire wound around a bobbin. Applying a current to the wire coil generates a magnetic field that actuates a plunger, which allows fluid to flow through the pump. Two manufacturing scenarios were presented for consideration, both of which begin with producing a coil assembly in Vietnam. The process is described as winding two different diameter wires consecutively around a bobbin, wrapping the wires with a layer of polyethylene terephthalate, and twisting the finish end of the first wire to the start end of the second wire. The ends are then soldered together and set in place using glue. In the first scenario, you state that the coil assembly will be manufactured as described above and shipped to China for the remainder of the assembly operations. The operational steps that occur in China involve soldering the coil wires to a Chinese printed circuit board assembly (PCBA), soldering two lead wires, and performing a simple functional test. The PCBA is described as a basic controller that consists of three diodes, five resistors, and a PNP transistor. Its function is to send power to the coil assembly and oscillate the timing of the electromagnetic coils. In the second scenario, you state that the Chinese PCBA will be shipped to Vietnam for the remainder of the assembly operations. The PCBA is connected to the Vietnamese coil assembly using the same operational steps as described in the first scenario. 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). CBP has held that whether an assembly process is sufficiently complex to rise to the level of a substantial transformation is determined upon consideration of the totality of the circumstances, which includes a review of the country of origin of the item’s components, the extent of the processing that occurs within a country, and whether such processing renders a product with a new name, character, and use. Assembly operations that are minimal or simple, as opposed to complex or meaningful, will generally not result in a substantial transformation. A significant factor in determining a product's country of origin is identifying the component (or components) that impart its essential character. Based upon your description of the manufacturing operations, we note that the final assembly operations in both scenarios are not particularly complex. Turning to the components of the Magnetic Coil Assembly, we find that the Vietnamese coil assembly imparts the character of the finished article and connecting a PCBA does not substantially transform the Vietnamese coil into a new and different article of commerce. Thus, based on the totality of the circumstances, the country of origin of the Magnetic Coil Assembly, part number 42405, will be Vietnam in both scenarios described above. 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 Paul Huang at paul.huang@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division