The country of origin of an ignition distributor for an automotive engine

N359247 March 24, 2026 OT:RR:NC:N2:201 CATEGORY: Origin Cheng Chao Desmond Lee Everspark Industries Sdn Bhd PTD 114234, Jalan Murni 15 Taman Perindustrian Murni 81400 Senai, Johor Malaysia RE: The country of origin of an ignition distributor for an automotive engine Dear Mr. Lee: In your letter dated February 26, 2026, you requested a country of origin ruling on an Ignition Distributor for an automotive engine. A distributor in an ignition system acts as a specialized rotary switch, routing high-voltage electricity from the ignition coil to the correct spark plug in the proper firing order. Driven by the camshaft, the distributor ensures precise timing of the spark for combustion. In your request, you state that the ignition distributor part number DST1830 is assembled in Malaysia, consisting of materials from Chinese, Malaysian or Taiwanese origin. A Bill of Materials (BOM) was submitted, along with the ignition distributor production process and other documents, illustrations, and a YouTube video showing the production work done in Malaysia. The production steps shown in your video from Malaysia include: Machining of shaft Injection molding of plastic casing and i nstallation of spring washer screws Fitting the distributor cap into the module groove of the shaft and then placing the DST1830 Shaft, with the drive gear section, into the hole of fixture L10/F-ST-01 Fit the rotor into the groove of the shaft and positioning the 4 pins of the distributor cap into the steel plate Machine and press the steel plate into the distributor cap. Placing M3.5X0.6 spring washer screws into the screw holes of the distributor cap Perform a final pass to secure both evenly. Ensure that the spring washers are flat after tightening. Installation of distributor, and rotor Applying of warranty sticker. Arrange all components on the shelf trolley. 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. With the facts and documentation presented, it is the opinion of this office that the Ignition Distributor’s components and subassemblies are substantially transformed during the manufacturing process in Malaysia. Thus, the country of origin of the complete automotive engine Ignition Distributor is Malaysia for marking purposes. As the country of origin of the subject item is Malaysia, the Section 301 Trade Remedy duties are not applicable to the Ignition Coil under consideration. Malaysia has been determined as the country in which the product was produced, therefore the Ignition Distributor may be marked “Made in Malaysia.” 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) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division