The country of origin of digital stick thermometers

N360390
April 24, 2026
OT:RR:NC:N1:105
CATEGORY: Origin Tirta Halim T Customs Broker, Inc.. 5777 W. Century Blvd. #965 Los Angeles, CA 90045 RE: The country of origin of digital stick thermometers Dear Mr. Halim: In your letter dated April 2, 2026, on behalf of your client, Fortunit Creative Co., Ltd., you requested a country of origin ruling on digital stick thermometers. Descriptive literature was provided for our review. The items under consideration are described as digital stick thermometers (models DMT412, DMT418, DMT437, and DMT4119), which are intended to measure the human body temperature orally, rectally or under the arm. The devices are reusable and designed for clinical or home use on people of all ages, including children under 8 years old with adult supervision. During operation, the user positions the thermometer’s thermistor probe at the measurement site. As the temperature of the heat source changes, the thermistor’s resistance varies accordingly. This resistance change is then converted and processed, displaying the measured temperature digitally on the screen while simultaneously activating a buzzer. Each of the four models are substantially similar with only a slight change in size and material. The DMT412 has a rigid tip and measures 12.4cm by 1.8cm by 1.1cm. The DMT 437 has a flexible tip and measures 12.4cm by 1.9cm by 1.1cm. The DMT418 has a rigid tip and measures 13.9cm by 2.3cm by 1.2cm and has a 21.7cm by 9cm screen. The DMT4119 also contains a rigid tip but measures 13.9cm by 2.3cm by 1.3cm and has a 22.6cm by 9.7cm display. Each of the thermometers are manufactured with components from Cambodia, China and Taiwan. The Cambodian-origin components include the enclosure, cover, dustproof case, chip on board (COB) and packaging. The Chinese-origin components include the mechanical thermometer (MT) movement, LCD, MT sheath, inner film, MT plunger, O-ring, buzzer, positive and negative conductive shrapnel, conductive bar, conductive point, battery, and positive and negative battery clamps. The sensor can be of Chinese or Taiwanese origin. The manufacturing process is conducted in Cambodia, commencing with MT COB bonding. Following a cleaning step, a chip is precisely aligned onto the printed circuit board (PCB) and secured using a hot press welding process. The operation then transitions to MT COB welding and sensor integration. MT COBs are

arranged on a plate fixture, and MT sensors are subsequently positioned on a layout fixture. These components are then soldered via an automated rotational cycle welding system. The subsequent stage involves MT movement assembly. The MT movement, with an integrated battery holder, is introduced into the movement vibration player and fed into the assembly machine. The positive and negative conductive spring pieces of the buzzer sheet, along with the conductive strip, are then fed into the machine. Next, the welded COBs are transferred to a conveyor belt, initiating the hot-pressing phase. A plunger is then inserted into the case, aligned with the sensing wire, until fully seated, ensuring the sensing wire protrudes above the thermometer head. The black head of the sensor is dipped in adhesive and pressed into the opening of the middle case. Finally, the thermometer head is pressed into its sheath, confirming the black end of the sensing wire is seated at the bottom of the steel sheath. The completed product undergoes a 24-hour drying period before final testing and packaging. 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). Regarding the origin of the digital stick thermometers, in our opinion, the processing in Cambodia, along with the Cambodian-origin COB, enclosure, cover, and dustproof case, transforms the Chinese/Taiwanese components into a new article with a name, character, and use different than the individual components. It is only after the manufacturing in Cambodia that the sensor and remaining minor Chinese components become a usable thermometer. This can be differentiated from the result in New York Ruling N349038, dated May 20, 2025, in which the sensor and the COB were both of Chinese origin. The immediate ruling contains a different origin for each of these two essential components. Accordingly, the country of origin of the digital stick thermometers (models DMT412, DMT437, DMT418, and DMT4119), is Cambodia. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). 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 P. Forkan Director National Commodity Specialist Division