The country of origin of ignition coils for an automotive engine

N360872 May 19, 2026OT:RR:NC:N2:201 CATEGORY: OriginShengrong ZhangZhuoye Automotive Technology (Thailand) Co., LTD.168/13, Moo 3, MapKha Subdistrict, Nikhom Phatthana District, Rayong ProvinceNikhom Phatthana 21180ThailandRE: The country of origin of ignition coils for an automotive engineDear Mr. Zhang:In your letter dated April 21, 2026 , you requested a country of origin ruling on ignition coils for automotiveengines.An ignition coil acts as an induction coil that transforms the low voltage (12v) from a car battery into thehigh voltage (thousands of volts) needed to operate spark plugs. This intense pulse of energy arcs across thespark plug gap, igniting the air-fuel mixture to power the engine.You state that these ignition coils are designed for modern passenger vehicles, such as the Toyota Camry,BMW 3 Series, Ford F-150, Volkswagen Golf, and others.In your request, you state that the ignition coils are assembled in Thailand, consisting of raw materialssourced from Thailand and China. You provided a Bill of Materials (BOM), along with production processdocuments, schematic diagrams, illustrations, and a manufacturing line mp4 video/YouTube showing theproduction work done in Thailand.The production steps shown in your assembly process diagrams from Thailand include:Primary winding - Install the primary skeleton into the fixtureSecondary skeleton insertion piece - Insert the secondary plug into the corresponding holeSecondary winding - Install the secondary skeleton into the fixtureSecondary soldering, installing connection pins - Tin the secondary coil that has been wound on thetwo plugs to make the secondary wire conductive with the plugs, and install it into the connecting pinsPrimary winding tape - Install the primary skeleton into the fixture, adhere the polyurethane tapetightlyAssembly of primary and secondary coils - After installing the T-shaped iron core and magnetic platesinto the primary coil assembly, install the primary coil into the secondary coil Assembly of iron core and partition - After assembling the C-type iron core with the partition, installthe coil assembly into itInstall the coil assembly into the casing - Use a pneumatic press to press the coil assembly into thehousing and install it in placeInstall the ignition module into the casing - Install the ignition module into the casing, twist the wiresand solder themSemi-finished product testing - Connect and test the semi-finished productsPotting - Preheat the tested semi-finished products on the tray, vacuum glue them, and cure themAttachment assembly - Assemble the high-pressure rod components and springs of the glued productOpen test - Perform a half minute open circuit test on the finished productFinished Product Testing - Conduct finished product testing on products with good road conditionsSection 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, everyarticle 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 toindicate to the ultimate purchaser in the United States, the English name of the country of origin of thearticle. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able toknow 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, byknowing where the goods were produced, be able to buy or refuse to buy them, if such marking shouldinfluence 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 thecountry of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBPRegulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, orgrowth of any article of foreign origin entering the United States. Further work or material added to an articlein another country must effect a substantial transformation in order to render such other country the “countryof origin” within the meaning of the marking laws and regulations.A substantial transformation occurs when, as a result of manufacturing process, a new and different articleemerges, having a distinct name, character or use, which is different from that originally possessed by thearticle or material before being subjected to the manufacturing process. See United States v.Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940).With the facts and documentation presented, it is the opinion of this office that thegnitioncomponents i coils andsubassemblies are substantially transformed during the manufacturing process in .Thus, the Thailand country of origin of the complete automotive enginegnitionis for markingpurposes. i coils Thailand The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Matthew Sullivan at matthew.sullivan@cbp.dhs.gov. Sincerely, (for)James P. ForkanDirectorNational Commodity Specialist Division