The country of origin of an oven spark plug assembly.

N352003
September 4, 2025
OT:RR:NC:N4:415
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 an oven spark plug assembly. Dear Mr. Chen: In your letter dated August 5, 2025, you requested a country of origin ruling. The product under consideration is described as a “spark plug” and will be used with a gas range to ignite the burner. Your submission indicates it consists of a cable, a ceramic insulator, a metal terminal, and a plastic connector. This request consists of two different country of origin scenarios. In the first configuration, all the components are sourced from Thailand except the ceramic insulator, which will be of Chinese origin. These components will be assembled in Thailand. In the second configuration, all the components are sourced from China except the ceramic insulator, which will be of Thai origin. These components will be assembled in Thailand. The assembly process in Thailand is described as follows: The cable and terminal are assembled. The ceramic insulator is fitted over the electrode end of the cable and affixed with glue. The ignition head (electrode) is cut to the desired length. The ignition head is polished. The spark plug assembly is tested and packaged. 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). In order to determine whether a substantial transformation occurs when components are assembled into completed products, all factors such as the components used to create the product and manufacturing processes that these components undergo are considered in order to determine whether a product with a new name, character, and use has been produced. No one factor is decisive, and assembly/manufacturing operations that are minimal will generally not result in a substantial transformation. We note that this is the same product ruled upon in New York ruling N350058, dated July 8, 2025, and in that ruling we found that the assembly in Thailand of the four components from China did not constitute a substantial transformation as the nature of the assembly process was not sufficiently complex nor meaningful as to create a product with a new name, character, or use. For this request, in the first scenario, since the majority of the components are from Thailand and are assembled into the final product in Thailand, we find that the country of origin of the spark plug assembly to be Thailand. In the second scenario, since the majority of the components are from China, we find that the country of origin of the spark plug assembly is 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 CBP Regulations (19 CFR 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 Kristopher Burton at [email protected].
Sincerely,
(for) Denise Faingar Acting Director National Commodity Specialist Division