The country of origin of a sun visor assembly for motor vehicles

N362678
July 21, 2026
OT:RR:NC:N2:206
CATEGORY: Origin Xiaozhen Qiao Joinhands International (Thailand) Co., Ltd. 538Moo6, Makham Khu Subdistrict, Nikhom Phatthana District, Rayong Province 21180 Thailand RE: The country of origin of a sun visor assembly for motor vehicles Dear Ms. Qiao: In your letter dated June 27, 2026, you requested a country of origin ruling on a sun visor for motor vehicles. The article under consideration is a sun visor assembly, Part Number JHZ-Z0029L, designed for installation on the roof of the driver’s and front passenger’s seats of a motor vehicle. The sun visor assembly consists of a foam body, inner frame, bracket assembly, mirror assembly, conductive plate assembly, roller shaft, micro switch, warning label and sun visor hook. The manufacturing process includes injection molding, EPP foam molding, fabric cutting, assembly, testing, and inspection. According to the submitted bill of materials (BOM), the cover fabric, upper foam, lower foam, bracket frame, bracket buckle, rotating shaft, end cap, spring plate bracket, inner frame, roller shaft, mirror frame, mirror cover, light guide plate, hook, and hook clip are sourced from Thailand. The plug, spring plate, conductive contact, conductive plate, roller pin, mirror, mirror spring plate, mirror cover shaft, mirror bulb, bumper, bulb wire harness, heat shrink tube, micro switch, seat belt warning label, and child seat warning label are sourced from China. The components are assembled in Thailand through a process that includes injection molding, EPP foam molding, fabric cutting, bracket sub assembly, mirror sub assembly, sun visor assembly, inspection, and packing. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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). In this case, the inner frame, mirror frame, bracket frame, upper and lower foam, and cover fabric constitute the principal components of the finished sun visor assembly. The major structural components are sourced

from Thailand and undergo molding, subassembly, final assembly, inspection and packing in Thailand. These manufacturing operations, together with the value added through Thai-origin components, labor, and packing, support a finding that a substantial transformation occurs in Thailand. Accordingly, the country of origin of the sun visor assembly is 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 Liana Alvarez at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division