The country of origin of motor control boards

N348878
June 2, 2025
OT:RR:NC:N2:220
CATEGORY: Origin Shoji Tsutsumi Toabo Corporation Crystal Tower 18F, 2-27, 1-Chome, Shiromi, Chuo-ku Osaka 540-6018 Japan RE: The country of origin of motor control boards Dear Mr. Tsutsumi: In your letter dated May 11, 2025, you requested a country of origin ruling on behalf of your client, Makita Corporation of America. There are three items under consideration, identified as Power Tool Controllers, with Model Numbers 631801C1, 631383D3, and 631493D3. Each of the Controllers are described as encapsulated printed circuit board assemblies (PCBAs) that control the operation of an electric motor in personal power tools, where Model 631801C1 is used in a sander/polisher and Models 631383D3 and 631493D6 are used in disc grinders. In your submission, you describe the production of the PCBAs as occurring in China by surface mounting and through-hole insertion of multiple components, such as resistors, capacitors, diodes, transistors, triacs, and a potentiometer, onto a bare printed circuit board. Also in China, a heat sink is mounted to the PCBA, wires are soldered onto the board’s terminals, and the product is shipped to Japan. In Japan, the boards undergo testing, calibration of the potentiometer, mounting to a plastic case, and resin is filled into the PCBA/case. Also in Japan, the encapsulated PCBA is inspected, tested, and packed for export to the United States. 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). Regarding the country of origin of the subject PCBAs, in our view, the production of the PCBAs in China by the surface mounting and through-hole insertion of multiple electronic components produces a PCBA of Chinese origin. However, in Japan, the calibration and addition of resin encapsulation does not substantially

transform the PCBA into a new product in name, character, or use. As a result, the Power Tool Controllers with Model Numbers 631801C1, 631383D3, and 631493D3, are considered products of China at the time of importation into the United States. 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 Karl Moosbrugger at [email protected]
Sincerely,
(for) Steven A. Mack Director National Commodity Specialist Division