The country of origin of a washing machine speed sensor

N350727
July 9, 2025
OT:RR:NC:N2:212
CATEGORY: Origin Long Chen Thai Jiuzhou Electron Co LTD 88/152 Moo 15 Bangsaotong Sub-District, Bangsaotong 10540 Thailand RE: The country of origin of a washing machine speed sensor Dear Mr. Chen: In your letter dated June 27, 2025, you requested a country of origin ruling. The merchandise under consideration, identified by part number 290D1187P006, is described as a washing machine motor speed sensor. The subject device is comprised of a printed circuit board assembly (PCBA), upon which is a Hall Effect sensor, that is enclosed within a plastic housing. Extending from the housing is a wire harness with a specialized electrical connector at the end. In use, the subject sensor is attached to the motor of a washing machine, which incorporates a magnet. The Hall Effect sensor within the subject device creates an electromagnetic field that, when broken by the magnet within the motor, sends an electrical signal to the control unit of the washing machine, which alerts the device to the appropriate speed of the motor. In your request, you state that the PCBA with the necessary Hall Effect sensor, is manufactured in China. This PCBA is then sent to Thailand where the wire harness, also of Chinese origin, is attached and then enclosed within the plastic housing. A Chinese connector is then attached to the end of the harness before the finished device is tested and packaged for shipment to the United States. 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 speed sensor, it is the opinion of this office that the Chinese PCBA with incorporated Hall Effect sensor imparts the character of the finished device. Further, the assembly process performed in Thailand is simple in nature and does not substantially transform the PCBA or other Chinese components into new and different articles of commerce. Based upon the facts presented, the country of origin of the washing machine motor speed sensor, part number 290D1187P006, 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