The country of origin of a door switch assembly

N351097
July 21, 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 door switch assembly Dear Mr. Chen: In your letter dated July 8, 2025, you requested a country of origin ruling. The merchandise under consideration is identified by part number 308D1107G002 and described as a door switch for use with a laundry dryer. The subject switch is comprised of an internal microswitch that is connected to a spring-loaded plunger. In use, the switch is installed in the door of a dryer. When the dryer door is in the closed position, the plunger is depressed, causing an electrical connection within the microswitch. This notifies the dryer that the door is closed. When open, the plunger releases, disconnecting the switch and signaling an open door position. In your request, you state that the manufacturing process occurs in Thailand with components primarily of Thai origin. The microswitch, which originates in Thailand, is placed within a plastic housing. Next, the plunger, spring, and lever are assembled onto the switch and covered with a plastic enclosure. Per the information provided, the spring is of Chinese origin while the remainder of the components originate in Thailand. The finished switch is then 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 door switch, it is the opinion of this office that the incorporated microswitch imparts the character of the finished device. Further, the only component that originates from outside of Thailand, the spring, is clearly substantially transformed through its incorporation into the finished device. As such, the country of origin of the door switch, part number 308D1107G002, will be 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 Luke LePage at [email protected].
Sincerely,
James Forkan Acting Director National Commodity Specialist Division