The country of origin of digital tire pressure gauges

N361406May 29, 2026OT:RR:NC:N1:105
CATEGORY: OriginFangyi TianAutowin Group LimitedFlat/Rm 08, 15/F, Witty Commercial Building1A-1L Tung Choi StreetMongkok KowloonHong KongChinaRE: The country of origin of digital tire pressure gaugesDear Ms. Tian:In your letter dated
May 9, 2026
, you requested a country of origin ruling on digital tire pressure gauges.Descriptive literature was provided for our review.The items under consideration are described as digital tire pressure gauges (model numbers SP003, SP010,SP024, and SP007), which are precise electronic tools that measure a tire’s inflation level by converting airpressure into an electrical signal. The exact measurement reading is displayed on an integrated digital LCDscreen, thereby eliminating the guesswork often associated with traditional analog dial gauges. In operation,each gauge is pressed onto the tire’s valve stem, allowing air pressure to act upon an internal electronicsensor, which then converts the pressure into data displayed on the backlit screen.While all models share fundamental similarities, minor variations exist in their housing design, color, andform. The SP003, measuring 77mm by 31mm by 23mm and weighing 25g, is composed of a top/bottom case,button, LCD screen, printed circuit board (PCB), rubber component, CR2032 battery, and auxiliary materials.The SP010, measuring 102mm by 65mm by 34mm and weighing 110g, includes a brass air inlet nozzle, TPEprotective sleeve, ABS top/bottom case, silicone rubber button, LCD screen, PCB board, rubber component,CR2032 battery, and auxiliary materials. The SP024, measuring 137mm by 56mm by 29mm and weighing45g, consists of an ABS top/bottom case, ABS battery cover, silicone rubber button, LCD screen, PCB board,rubber component, AAA battery, and auxiliary materials. Finally, the SP007, measuring 11mm by 2.4mm by4.4mm and weighing 48g, is composed of an ABS top/bottom case, silicone rubber button, LCD screen, PCBboard, rubber component, CR2032 battery, and auxiliary materials. The digital tire pressure gauges are manufactured in Malaysia through a substantially similar process,utilizing components sourced from both Malaysia and China. Malaysian-sourced components include the topcase, bottom case, button, LCD screen, PCB board, rubber components, and various auxiliary components.
Specifically, for the SP010 model, a brass inlet nozzle with a deflation button and a plastic protective sleeveare also sourced from Malaysia. Components from China primarily consist of batteries and raw rubber andplastic materials.The manufacturing process for the SP010 model begins in Malaysia with the CNC machining, electroplating,and assembly of its copper head, followed by the remaining processing steps common to all gauges. InMalaysia, the plastic upper and lower housings undergo injection molding, with spray painting applied ifrequired. This is followed by overmolding injection for the upper and lower covers and then the injection ofglue for the rubber components. The LCD panel, circuit board, and battery are procured as complete unitsand prepared for installation. The assembly sequence involves installing the circuit board and batteryretaining clip, welding the circuit board, battery, and clamp plate, and subsequently installing the LCDscreen, battery, and rubber part. The final steps include screwing together the upper and lower covers,followed by 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 asubstantial 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 tire pressure gauges, it is our opinion that the manufacturing and assemblyprocess performed in Malaysia transforms the individual components from China into finished digital tirepressure gauges. The plastic and rubber raw materials as well as the batteries each have a change in name,character, and use. Consequently, we conclude that the country of origin of the digital tire pressure gauges(model numbers SP003, SP010, SP024, and SP007) is Malaysia, which is where the assembly process occurs,most of the components are manufactured, and the Chinese components are transformed into finished digitaltire pressure gauges.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Jason Christie at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division