The Country of Origin of an automotive starter.

N361515June 3, 2026OT:RR:NC:N2:201
CATEGORY: OriginSteven CottoBaker McKenzie LLP815 Connecticut Ave NWWashington, DC 20006RE: The Country of Origin of an automotive starter.Dear Mr. Cotto:In your letter dated
May 13, 2026
, you requested a country of origin ruling on a starter for an automotiveengine from Malaysia, on behalf of your client Motorcar Parts of America, Inc.The item under consideration has been identified as an automotive starter, Part number 17825N.A starter in a motor vehicle is an electric motor that, when activated, engages with the engine’s flywheel torotate the crankshaft and initiate the combustion cycle. It is typically powered by the vehicle’s battery andcontrolled by a solenoid that both sends high current to the motor and pushes the starter gear into mesh withthe flywheel teeth. Once the engine starts, the starter disengages to prevent damage, as the engine’s owninertia then sustains the starting process.In your request, you claim that the starters are manufactured in Malaysia, and consist of parts sourced fromChina, Malaysia, and the United States. You provided a Bill of Materials (BOM)along with , a videoproduction process.describing the The starter is comprised of several parts and assemblies, including:Drive End (DE housing)Stop collarRetainer ringDrive assemblyStationary gear kitPlanetaryshaft Planetary gearShift leverShift lever padGrommetSolenoid assembly
Field case assemblyArmatureBrush holder assemblyCommutator End (CE) housingBrush holder screwSolenoid screwDrive cover, and theThrustcollar You claim, and this office agrees that consistent with CBP precedent, the solenoid assembly andprevious field case assembly are treated as essentialcomponents of the finished starter . You provided video evidence both are manufactured in Malaysia.to substantiate thatthe solenoid assembly and field case wholly You state that the following assembly process occurs in Malaysia and result in the creation of a workingstarter:Apply grease in DE BushingInstallation of Stationary Gear Cover & Drive Gear Assembly into Planetary Shaft with greaseInstall Stop Collar Retainer RingInstallation of Shift Lever - Apply Shift Lever with greaseInstall Gear Track Stationary Gear Seal, Shift Lever Pad, Grommet Planetary Gears into DE Housing. Apply Planetary Gears with greaseInstall Drive PlateInstall ArmatureInstall Field CaseInstall Brush HolderApply grease in CE BushingInstall CE Housing install Brush Holder Screw and markingInstall Thru BoltsInstall Solenoid AssemblyInstall Solenoid ScrewInstall Brush Holder Lead Wire Terminal on Solenoid Motor Post and Field Case Lead NutPackagingWhen 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).Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of originof the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may,by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940).
Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the countryoforigin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP-- Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an articlein another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations.With the facts and documentation presented, it is the opinion of this office that the components andstarter’s subassemblies are substantially transformed during the manufacturing process in MalaysiaThus, the country. of origin of the completefor markingurposesMalaysia.s the country of origin of the subject starter p is Aitem is, the Section 301 Trade Remedy duties arenot applicable,the may be marked Malaysia and alternator“Made inMalaysia.” 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 Matthew Sullivan at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division