The country of origin of a gearcase

N359527 April 3, 2026 CLA-2:OT:RR:NC:N1:104 CATEGORY: Origin Martin Schaefermeier Cassidy Levy Kent (USA) LLP 2112 Pennsylvania Avenue NW, Suite 300 Washington, DC 20037 RE: The country of origin of a gearcase Dear Mr. Schaefermeier: In your letter dated March 6, 2026, you requested a country of origin ruling on behalf of your client, Whirlpool Corporation. The product in question is referred to as the Gearcase M8, Whirlpool SKU No. W11673973 (gearcase). The gearcase is designed to be used in domestic washing machines with capacities exceeding 10 kilograms. The primary components of the gearcase are the spin tube, upper housing, lower housing, washing shaft, input shaft, and the two gears (the planet gear and the ring gear). It is designed to connect to the agitator, a basket attachment, the tub, tub seal and rotor, and in use, converts the power of the motor into an action that allows the washer drum of a washing machine to agitate and spin. With respect to origin, the gearcase is produced in Thailand using components of Chinese, Korean and Thai origin. Prior to the final assembly processes, unfinished major components, which include the spin tube and shafts (washing and input shafts), are manufactured in China and exported to Thailand for further processing. In Thailand, the tube and shafts undergo rough and fine grinding processes, burring, threading, and rough and fine machining to produce the inner and outer diameters. The shafts also undergo various drilling processes, and the washing shaft is also splined in Thailand. The upper housing is manufactured in China and exported to Thailand to undergo stamping and fine machining processes. The lower housing is manufactured in China and exported to Thailand to undergo rough and fine machining to form the inner and outside diameters. Afterward, the housing undergoes burring, cleaning and oiling processes. The plastic planet and ring gears are manufactured in Thailand using an injection molding process and are then subjected to cutting and heat pressing processes. In Thailand, the individual components mentioned above are combined with other components to form subassemblies. For instance, bushings, seals, and an input shaft are pressed into the lower housing to form the lower housing subassembly. To form the gear subassembly, a stop ring, upper carrier, lower carrier, washing shaft, planet gear shaft and planet gear are pressed and riveted to each other. Next, a spin tube and upper housing are heat pressed, laser welded, and combined with bushings to form the spin tube subassembly. During the final assembly, which also occurs in Thailand, the subassemblies are joined by pressing, welding, and completing sealing processes. Oil and lubricant sourced from South Korea is applied as needed. Afterwards, the completed gearcase is subjected to various inspections and tests, and once complete, the gearcase is prepared for shipment. 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). 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 all the operations that occur within that country. Here, components from China are machined in Thailand and then assembled to each other in Thailand to produce subassemblies, which are afterwards combined in Thailand to form a gearcase. When considering the totality of the circumstances, this office finds that the assembly processes that occur in Thailand, taken as a whole, are sufficiently complex and meaningful as to result in a substantial transformation, such that the non-originating components lose their individual identities and become an integral part of a new article, possessing a new name, character and use, namely, a gearcase. Based on the processes described in the submission, we find the country of origin of the complete Gearcase M8 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 Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division