The country of origin of an EV fuse

N350176
July 2, 2025
OT:RR:NC:N2:212
CATEGORY: Origin Somjed Nirundonwanich Synoelec Technology (Thailand) Co.,Ltd. 500/102 Moo 3 Rayong 21140 Thailand RE: The country of origin of an EV fuse Dear Mr. Nirundonwanich: In your letter dated June 13, 2025, you requested a country of origin ruling. The merchandise under consideration is identified by product number RS309-MF-14LB63A-TH and described as an Electric Vehicle (EV) fuse. The subject device is comprised of a silver strip and Quartz sand encased within a porcelain tube. You state that the fuse is primarily used within EVs to act as passive backup protection for various electrical systems within the vehicle. When too much current passes through the silver strip within the device, excessive heat is generated. This heat melts the strip, which breaks the circuit and ceases electrical flow through the system. In your request, you state that the manufacturing process occurs in Thailand. This process begins with a Chinese silver strip being bent and crimped before it is placed within the porcelain tube, also of Chinese origin. The tube is then filled with Quartz sand that originates from Germany before the finished device is sealed, marked with product information, and packaged for shipment to the U.S. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, 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 subject fuse, it is the opinion of this office that the silver strip imparts the character of the finished device as it is the essential electrical component. Further, the process performed in

Thailand is simple in nature and does not substantially transform the Chinese components into new and different articles of commerce. Based upon the facts presented, the country of origin of the EV fuse, product number RS309-MF-14LB63A-TH, will be China. 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 Luke LePage at [email protected].
Sincerely,
James Forkan Acting Director National Commodity Specialist Division