The country of origin of a fuel pump

N356398
December 18, 2025
OT:RR:NC:N1:102
CATEGORY: Origin Hui Wang TradeSmart USA LLC 1370 Valley Vista, Suite 200 Diamond Bar, CA 91765 RE: The country of origin of a fuel pump Dear Ms. Wang: In your letter dated November 24, 2025, you requested a country of origin ruling on behalf of ACCAUTO (Thailand) Co., Ltd. Descriptive information regarding the assembly process was provided with your submission. The product at issue is referred to as a fuel pump. The fuel pump is an assembly that incorporates an electrically powered pump to continuously supply fuel from the tank to the fuel system. The assembly primarily consists of a pump core and various subassemblies. The fuel pump is used in all-terrain vehicles, trucks, utility vehicles, and vehicles for passenger and commercial use. The final assembly of the fuel pump occurs in Thailand using subassemblies and components sourced from Thailand and China. Prior to the final assembly, the assembly of the pump core begins by press-fitting a shaft from China into a rotor core from China. Afterwards, insulation is installed, the rotor is press-fit into a commutator from China, and wire is wound onto the rotor. Next, processes such as welding, injection molding, turning and deburring are completed which are followed by the assembly of an inductive core and coil. Subsequently, a brush from China is riveted to the coils and a stator from Thailand is magnetized. A pump casing is then assembled, a bearing is inserted into a bore of the inlet plate, which is followed by the installation of an end cap, a stator and a rotor. Finally, an impeller from Thailand is press-fit onto the shaft of the rotor, a cover pad from China is pressed into the hole of an outlet plate and the resulting assembly is then pressed into one end of the pump shell. Both ends of the pump casing are crimped to seal the subassembly. The plastic flange subassembly is produced by securing a valve into the exhaust port of a plastic flange from Thailand using a snapping process. To produce the housing subassembly, a diaphragm pad from China is installed and sealed into a reservoir from Thailand.

The production of the fuel level sensor subassembly begins by soldering copper wires of the wiring harnesses from Thailand to the conductor area of the resistor, which is then installed into the resistor bracket from Thailand. A shaft is then pressed into the center hole of the float arm bracket, an elastic contact is pressed into one end of the same bracket, and the float arm bracket is then aligned with the resistor bracket. Subsequently, a float is riveted to the float arm bracket, a cover is installed, and the float arm assembly is inserted into the open end of a bracket. During the final assembly, the aforementioned subassemblies and other components such as waved pipes from Thailand, a filter from Thailand, a pressure regulator from China and a strainer from China are assembled to each other using processes such as press-fitting, inserting and soldering. These processes also include welding a plastic flange and a wiring harness in place and pressing rods into their respective holes. Lastly, a fuel level sensor subassembly and a dust cover are installed. Throughout the various processes, the fuel pump undergoes various inspections and testing. 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). CBP has held that whether an assembly process is sufficiently complex to rise to the level of a substantial transformation is determined upon consideration of all the operations that occur within that country. Here, components from Thailand and China are assembled together in Thailand to produce subassemblies, which are then combined with other components in Thailand to form a fuel pump assembly. When considering the totality of the circumstances, this office finds that the assembly processes that occur in Thailand, taken as a whole, are sufficiently complex and meaningful as to result in a substantial transformation, such that the non-originating components lose their individual identities and become an integral part of a new article, possessing a new name, character and use. Based on the processes described in the submission, we find the country of origin of the fuel pump assembly is 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 Sandra Martinez at [email protected].
Sincerely,
(for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division