The country of origin of an ultrasonic sensor module

N352230
August 28, 2025
OT:RR:NC:N1:105
CATEGORY: Origin Emma Han ADW Electronics Sdn. Bhd. 9, Sekseyen 7, Jalan BS 7/1C, Taman Perindustrian Bukit Serdang 43300 Seri Kembangan Selangor, Malaysia RE: The country of origin of an ultrasonic sensor module Dear Ms. Han: In your letter dated August 11, 2025, you requested a country of origin ruling on an ultrasonic sensor module. Descriptive literature was provided for our review. The item under consideration is described as an ultrasonic sensor module (Part No. 0060858035), which is a functional component in the automatic water filling system of smart refrigerators. It consists of a front plastic bracket and an ultrasonic sensor module, assembled as a single integrated unit. The primary function of the component is to detect water levels inside a container using ultrasonic signal transmission and reception. In operation, the module’s processor sends a short pulse to its trigger pin, which allows the transmitter to send out a burst of ultrasonic sound waves. As soon as the sound waves are sent, the module’s echo pin rises, starting a timer. The ultrasonic waves travel away from the sensor at the speed of sound and bounce off any object in their path. The reflected waves then travel back to the sensor. When the echo is detected by the receiver, the echo pin goes low, stopping the timer. The total time the echo pin was high corresponds to the time it took for the sound to travel to the object and back. This calculates to a distance and ultimately a level in the container being filled. The product measures 22cm in length by 9.3cm in width by 0.85 cm in height. The manufacturing process occurs in Malaysia with components from Malaysia and China. The Malaysian components include the bracket, which provides the structural housing for precise probe positioning and integration with the refrigerator system, and some packaging including the label and anti-static packaging bags. The Chinese components include the plastic housing, rubber ring, piezo element, wire harness, printed circuit board (PCB), solder wire, label, and potting glue. In Malaysia, the Chinese-origin ultrasonic sensor components (including the piezo element, PCB, wire harness, plastic housing, and rubber parts) undergo a multi-stage assembly process that produces the finished functional sensor modules. The process starts with the assembly of the core components (i.e., PCB alignment with the piezo element, soldering, and trimming excess pins). The process then moves into the electrical validation (capacitance measurement and polarity verification) stage followed by waterproof sealing (piezo

element insertion into the rubber sleeve and shell, and sealant curing). Finally, the individual module undergoes functional testing, which includes echo testing to confirm detection capability. Two completed sensor modules are then integrated with a plastic bracket to form the dual-sensor water level detection assembly. This final configuration undergoes additional system-level functional testing to ensure their proper pairing and synchronization. When determining the country of origin, 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). Based upon the facts presented, it is the opinion of this office that the assembly of the ultrasonic sensor module in Malaysia does not substantially transform the individual Chinese components into a new article with a name, character, and use. The components undergo simple assembly in Malaysia that includes soldering, cutting, gluing, and placing the different components. The items do not have a different purpose when they leave China compared to the final product when it leaves Malaysia. The addition of the Malaysian plastic bracket holds the ultrasonic sensor in place, but it is still the ultrasonic sensor performing the essential function of the finished article. Additionally, the testing in Malaysia ensures that the sensor will operate but does not change the function of the unit. Accordingly, the country of origin of the ultrasonic sensor module (Part No. 0060858035) 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 Jason Christie at [email protected].
Sincerely,
(for) James Forkan Acting Director National Commodity Specialist Division