The country of origin of cooktop switch harnesses

N362603
July 15, 2026
OT:RR:NC:N2:220
CATEGORY: Origin Long Chen Thai Jiuzhou Electron Co Ltd 88/152 Moo 15 Bangsaotong Sub-District Bangsaotong 10570 Thailand RE: The country of origin of cooktop switch harnesses Dear Mr. Chen: In your letter dated June 25, 2026, you requested a country of origin ruling. The merchandise under consideration is described as a switch harness for use in a gas range and identified by the following part numbers: 164D9790G, 191D9236G, 301D2124G, 301D2125G, 301D2126, and 311D5137G. We note that the different variations are virtually identical and only differ by the specific appliance with which they will be used. The subject device is comprised of a set of insulated cable conductors with multiple compression switches attached as well as an electrical connector at the end. You state that the subject switch harness is used as a component in a gas range in order to act as the ignition trigger for the cooktop. In your request, you propose three different manufacturing scenarios that cover all identified models of the cooktop switch harness. In scenario 1, you state that the insulated wire is made in China and the switch components are made in Thailand. In scenario 2, you state that the insulated wire, switch cover, and cam button are made in China and the switch base is made in Thailand. In scenario 3, you state that the switch cover and cam button are made in China and the switch base and insulated wire is made in Thailand. In all three scenarios, the manufacturing process takes place in Thailand where the wire harness is placed within the switch base before the remaining switch parts, including the contacts and cam buttons, are assembled on top of the base. The switch cover is then placed over the assemblies and the finished harness is tested and packaged for export to the United States. When 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). Regarding the origin of subject switch harnesses, it is the opinion of this office that the insulated wire imparts the functional character of the device. Further, the assembly procedures performed in Thailand are simple in nature and do not substantially transform the Chinese and Thai components into new and different articles of commerce. Therefore, the country of origin for the switch harnesses, part numbers 164D9790G, 191D9236G, 301D2124G, 301D2125G, 301D2126, and 311D5137G, will be China for scenarios 1 and 2. The country of origin for these switch harnesses in scenario 3 will be Thailand. 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 Gary Chaffee at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division