The country of origin of a speed sensor assembly for an automobile

N354216
October 9, 2025
OT:RR:NC:N2:212
CATEGORY: Origin Samantha Hayward International Custom Services, Inc. P. O. Box 339 Pewaukee, WI 53072 RE: The country of origin of a speed sensor assembly for an automobile Dear Ms. Hayward: In your letter dated September 25, 2025, you requested a country of origin ruling on behalf of your client, TMI EP LLC. The merchandise under consideration is identified by part numbers 20123001 and 20123003 and described as wheel speed sensors. The devices are comprised of a magnetic sensor Integrated Circuit (IC) within a plastic enclosure and attached to an insulated cable. In use, the speed sensor is attached within the wheel of a vehicle and acts as a transducer by creating a magnetic field that, when interrupted by the presence of the wheel, creates an electrical signal that is sent to the Electronic Control Unit (ECU) for interpretation. This signal is used to determine the speed of the wheel and is used within the tire monitoring system of the vehicle. In your request, you state that the manufacture of the finished good begins with the creation of the sensor IC, part numbers TLE5045IC-R100 or TLE5046IC-PWM2, in Malaysia. This sensor is then sent to China where it is cut and bent to fit within the carrier assembly and the remainder of the housing components, all of Chinese origin. The sensor head is then attached to the Chinese cable 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 article, it is the opinion of this office that the speed sensor, which is manufactured in Malaysia imparts the critical function of this device. The assembly process that takes place in China is simple in nature and would not effect a substantial transformation of the speed sensor. Based on

the facts presented for the speed sensor assembly, part numbers 20123001 and 20123003, the country of origin will be Malaysia. 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,
(for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division