The country of origin of thermal spray coating machines

N361836June 11, 2026OT:RR:NC:N1:105
CATEGORY: OriginKerry WangBraumiller Law Group PLLC5220 Spring Valley Road, Suite 200Dallas, TX 75254RE: The country of origin of thermal spray coating machinesDear Ms. Wang:In your letter dated
May 27, 2026
, on behalf of your client, Oerlikon Metco (US) Inc., you requested acountry of origin ruling on thermal spray coating machines. Descriptive literature was provided for ourreview.The items under consideration are described as thermal spray coating machines, which are designed to applydurable, wear, and corrosion-resistant coatings to substrates using various thermal spray processes, includingplasma spray, high-velocity oxygen fuel (HVOF), and flame spray. Each machine platform consists of twoprimary modules, which house internal sub-systems assembled from globally sourced components.Specifically, the Surface Platform integrates a coating module and a process module, which collectivelyprovide all necessary components and sub-systems for a complete thermal spray coating operation.The coating module is engineered to support up to three distinct thermal spray processes. Its core componentcan be configured for single or triple cathode plasma spray, HVOF (gas or liquid-fuel), and combustionpowder spray capabilities. The process module contains ancillary components essential for supporting thecoating module’s operation. This module includes a multicoat controller, a process management system, apower supply, a universal junction and monitoring unit, a gas management system, electrical distribution, aheat exchanger with two-gun cooling water circuits, and a maintenance access door.The surface platform thermal spray coating machine integrates components sourced globally, with finalconsolidation, electrical integration, calibration, functional testing and assembly occurring in Liechtenstein.Switzerland is a primary contributor, providing the core process and electronic infrastructure, including thepower control cabinet (PCC), main machine cabinet (MMC) media management units, human machineinterface (HMI) operator panels, interface control cabinets (ICC), SinglePro powder feeder modules, junctionand monitoring assembly (JAM) units, and control unit valve (CUV) media cabinets. From Switzerland alsocome ancillary electrical extension modules, power supplies, robotic teaching tools, gas control equipment,and structural robot mounting pedestals. Furthermore, the heavy mechanical structure of the thermal spraybooth, its acoustic containment panels, structural hardware, a heat exchanger unit for the dual-circuit process
cooling, dust extraction filtration tools, vacuum units, and maintenance accessories are all sourced fromSwitzerland.Japan manufactures the primary robotic manipulator, specifically the FANUC M-710iC/50 robot assembly,essential for precision gun handling. Germany contributes the heavy part-handling manipulator sub-system,which includes the Takttisch indexing table, Robax-500 swing arms, specialized face plates, and integratedpneumatic rotary walls. Germany also supplies protective dark windows for the booth and integratedcommunication components for the cooling system’s heat exchanger.Further European contributions include transparent glass for the booth from Belgium, and internal LEDlighting fixtures along with heavy chiller hose assemblies from Italy. Slovakia provides integrated specializedflexible vacuum hoses. Finally, the United States is the source for the core application components,manufacturing the HVOF hybrid spray guns, high-pressure orange powder feed hose assemblies, andmulti-use air, oxygen, and fuel connection lines. Basic hose clamps are also sourced from the United States.The final assembly, mechanical and electrical integration, and system-level testing of the surface platform areperformed in Liechtenstein. This comprehensive process integrates a collection of modules and componentsinto a fully operational thermal spray coating system ready for its intended industrial application. Theassembly process involves six core steps and requires approximately 620 labor hours to complete.The process starts with core system testing, which includes an electrical function test, leak test, softwareinstallation, and calibration of the mass flow controller connecting to the feeder and multi-coat controller.The subsequent step is mechanical integration, requiring personnel to prepare and mark the mounting field.Following this, the coating module is positioned, the silencer is installed, and the extraction system isconnected. Components are then placed according to the established layout, and cable ducts are routed as perthe cable layout. The robot is installed within the coating module, and the K2 carousel is fitted, including thebulkhead and pneumatics. The chiller is filled, water hoses are connected, gas hoses are laid, kerosene isconnected, and the spray gun is installed. Electrical integration follows, involving the preparation andlabeling of cables. All components are then wired before power is supplied to the unit, and various additionaltasks are completed.The next phase is system start-up, which necessitates complete testing of the surface platform against apredefined checklist. Upon completion of the start-up system testing, the surface platform undergoes afactory acceptance test (FAT) conducted by an integration technician to verify product function and quality.Once all preceding procedures are finalized, the mechanical, electrical, and installation components aredisassembled for packaging. Following complete disassembly, the materials are prepared for importation tothe United States.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 thermal spray coating machines, it is our opinion that the assembly, testing andcalibration being performed in Liechtenstein substantially transforms the individual components sourcedfrom various countries. While some major subassemblies are created in Switzerland, it is not until thecomplete unit is created in Liechtenstein that there is a functional robot capable of spraying. The total numberof man hours required to assemble the product in Liechtenstein, along with the complexity of the constructionand the skill required by the workers, involves more than a simple assembly process. Accordingly, in our
opinion, the surface platform undergoes a substantial transformation in Liechtenstein, where it receives a newname, character, and use. Therefore, the country of origin will be Liechtenstein, which is where theindividual components are transformed into fully functional thermal spray coating machines.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