The country of origin of an automotive alternator.

N361517June 4, 2026OT:RR:NC:N2:201
CATEGORY: OriginMr. Steven CottoBaker McKenzie LLP815 Connecticut Ave NWWashington, DC 20006RE: The country of origin of an automotive alternator.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 first item under consideration has been identified as an alternator, Part number 15732N, which you stateis designed specifically for 2007-2015 General Motors vehicles, including Chevrolet Silverado 1500,Chevrolet Tahoe, GMS Sierra 1500, and Cadillac Escalade fitted with the 4.3L, 4.8L, 5.3L, 6.0L, 6.2L or6.8L V8 engine.The second item under consideration has been identified as an alternator, Part number 100-60110-FE, whichyou state is designed specifically for 1999-2023 Freightliner applications, including Freightliner Cascadiaand FLD120SD fitted with the L6 engine.An automotive alternator is an electrical generator that converts mechanical energy from the engine intoalternating current (AC). It continuously recharges the vehicle's battery and powers all electrical systems,such as the lights, radio, and dashboard, while the motor is running. By changing AC power into usable directcurrent (DC), it ensures your car's electronics operate reliably without draining the battery.In your request, you state that the part number alternator s15732Nand 100-60110-FE are manufactured inMalaysia and consist of parts sourced from China and Malaysia. You provided a Bill of Materials (BOM),along with a video describing the production process.The alternators are comprised of the pulley, drive-end shield, roller bearings, rotor, stator, collector-ring and shield, rectifier and protective cap. Consistent with CBP precedent, the stator is an essential component of thefinished alternator and is manufactured in Malaysia.
The alternator is comprised of several parts and assemblies, including:PulleyDrive-End (DE) ShieldRoller BearingsRotorStatorCollector-Ring and ShieldRegulatorRectifier, and aProtective CapYou claim, and this office agrees that consistent with previous CBP precedent, the rotor and statorassemblies, are treated as essential components of the finished starter. You provided video evidence to rotor and stator assemblies,substantiate that both the are wholly manufactured in Malaysia.You state that the following assembly process occurs in Malaysia and result in the creation of a workingalternator:DE bearing-Press and retainer assemblyApply protecting oil to rotorAssemble rotor & pulley to DE housingAssemble pulley, washer and nut, then tightenStator installed to DE housingAssemble SRE bearing and washer on rotorMarriage press SRE and DE housingTightening of brush holder, regulator and rectifier installationRectifier cover and insulator assemblyEnd of-line TestingPackagingWhen 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 article
in 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 alternator’s componentsand subassemblies are substantially transformed during the manufacturing process in Malaysia. Thus, thecountry of origin of the complete alternator for marking purposes is Malaysia. As the country of origin of thesubject item is Malaysia, the Section 301 Trade Remedy duties are not applicable, and the alternator may bemarked “Made in Malaysia.”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