The country of origin of an expansion tank

N359542 March 30, 2026 OT:RR:NC:N2:206 CATEGORY: Origin Xiaozhen Qiao Joinhands International (Thailand) Co., Ltd. No. 576/1, Moo 1, Phananikhom Subdistrict, Nikhom Phatthana District, Rayong Province 21180 Thailand RE: The country of origin of an expansion tank Dear Ms. Qiao: In your letter dated March 7, 2026, you requested a country of origin ruling on an expansion tank. The article under consideration has been identified as an expansion tank or expansion reservoir (Part Number JX-A189-2), which is a core supporting component in the cooling systems of vehicles, agricultural machinery, and other equipment. It is manufactured from reinforced polypropylene (PP) and poly-amide, which offer resistance to high/low temperatures and corrosion. The expansion tank is produced via precision injection molding and welding processes. It typically features a flat rectangular prism shape or a customized structure designed to fit specific installation spaces. The tank body incorporates both longitudinal and transverse reinforcing ribs as well as metal inserts to ensure pressure and burst resistance (capable of withstanding pressures over 600 kPa). It employs a semi-transparent design with clearly marked MAX and MIN liquid level indicator lines. The top is equipped with a sealed cap that includes a pressure relief valve. The sides feature a filling port, inlet/outlet ports, and mounting holes for sensors. It comes with mounting brackets and hose clamp structures, supporting installation via screw fixing or welding. When the equipment heats up, the coolant expands, and the excess fluid flows into the expansion tank for storage. When the equipment cools down, the system pressure drops, and the stored coolant is drawn back into the main tank. This prevents the system from overheating due to coolant shortage and reduces the frequency of antifreeze top-ups. Within the sealed cooling system, the tank absorbs and balances pressure fluctuations in the circuit. The pressure relief valve on the tank cap automatically opens to release air when pressure becomes excessive, preventing pipes from bursting. Simultaneously, it helps maintain proper positive pressure within the system, which aids in purging air and raises the boiling point of the coolant. The tank separates air bubbles formed during coolant circulation, preventing "airlocks" that hinder cooling efficiency and reducing the impact caused by bubble collapse. This lowers the risk of cavitation inside the engine water jacket, thereby protecting core components. The semi-transparent tank body and clear level markings allow users to visually check the coolant volume. Some models support the installation of a level sensor. When the liquid level falls below the minimum mark, an alarm can be triggered to remind the user to add coolant promptly, preventing potential equipment damage due to fluid shortage. According to the bill of materials (BOM) and production flowchart submitted with your request, the body of the tank (upper and lower) is made by mold injection in Thailand. The float bowl and floating component are also made in Thailand. The pressure cap, copper pipes and main pipe, sensor, gasket, and clasp are made in China and imported to Thailand for final assembly with the Thai tank body, float bowl, and floating component. 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). It has been a long-standing CBP position that simple assembly of components does not result in a substantial transformation. As a result, we must determine the character of the expansion tank. Although the pressure cap and sensor are integral components of the expansion tank that render the tank its functionality for the designed purpose, the body of the tank that holds the fluids is as equally important. Taking into account the fact that the final assembly occurs in Thailand, and the cost of Thai components and labor is over 75 percent of the total cost, it is the opinion of this office that the country of origin for the expansion tank or expansion reservoir (Part Number JX-A189-2) will be 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 Liana Alvarez at liana.alvarez@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division