The country of origin of an oxygen sensor

N360437 April 17, 2026 OT:RR:NC:N1:105 CATEGORY: Origin Alexandra Brown Meeks, Sheppard, Leo, & Pillsbury 352 3rd Street, Suite 202 Laguna Beach, CA 92651 RE: The country of origin of an oxygen sensor Dear Ms. Brown: In your letter dated April 3, 2026, on behalf of your client, SIP VolksElektronik Co., Ltd., you requested a country of origin ruling on an oxygen sensor. Descriptive literature was provided for our review. The item under consideration is described as an automotive exhaust gas oxygen sensor designed for installation in a motor vehicle exhaust system. The sensor is used to detect the oxygen content of exhaust gas and generate an electrical signal used by the vehicle’s engine management system to ensure optimal air-fuel ratio control, leading to improved fuel efficiency and reduced exhaust emissions. The oxygen sensor is constructed of material from China, Japan, and Thailand. The Chinese components include the stainless-steel protective tube, terminal clips, porcelain, insulation sleeve, fluorine rubber plug, threaded stainless-steel hexagonal base, sleeve, shaped washer, zirconium powder (a zirconia ceramic matrix is formed, providing an oxygen ion conduction channel and constituting the core structure of the sensor), corrugated tube, high temperature wire, connector set, glass fiber tube, white plastic protective cover, and packaging. The Japanese-sourced platinum (0.03 grams) serves as an electrode and enhances the sensor’s response speed. The powder cake, compressed ceramic powder (Talc) acting as a hermetic seal against exhaust gas, is produced in Thailand. The manufacturing process for the oxygen sensor begins in Thailand with zirconium powder, which is combined with binder materials to create a ceramic slurry. This slurry undergoes milling, degassing, filtering, and casting into a thin film. The film is then cut into sheets, stacked, heat-pressed, and oven-dried. Subsequently, the film is punched into shape, and metal paste is screen-printed onto it before a second baking. Multiple printed film layers are then stacked and bonded, followed by cutting and sintering each film strip. These pieces are fired at extremely high temperatures, and the finished films are tested for temperature resistance, stability, and insulation. Finally, other components are cut and welded before being assembled into the complete oxygen sensor. When determining the country of origin, 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). Regarding the origin of the oxygen sensor, in our opinion, the individual components sourced from China and Japan, including the raw zirconia powder, ceramic powder, and platinum, are transformed into a sensor capable of detecting oxygen in Thailand. The processing in Thailand requires fourteen complex machines, skilled labor, and considerable time. Prior to manufacturing in Thailand, the powders and discrete components have no capability to detect oxygen or generate the output signal required for automotive engine management. After Thailand processing and assembly, the article is dedicated to the specific end use of oxygen measurement in exhaust gas. Accordingly, the country of origin of the oxygen sensor 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division