RE: The country of origin of throttle bodies

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N363816 August 27, 2026 OT:RR:NC:N1:102 CATEGORY: Origin Xingzi Zang Hongke Electric (Thailand) Co., Ltd. 213/2 Village No. 3, Thung Sukhla Subdistrict Sriracha District Chonburi 20230 Thailand RE: The country of origin of throttle bodies Dear Ms. Zang: In your letter dated July 29, 2026, you requested a country of origin ruling on throttle bodies. The products at issue are throttle bodies, specifically item numbers E57C and E87-1. These components are part of a motor vehicle’s engine air-intake system. They are designed to execute commands received from the engine’s Electronic Control Unit (ECU) by opening and closing the throttle plate to control the volume of air intake. Concurrently, they provide output signals that allow the control system to monitor the working status of the throttle body. Both throttle bodies are assemblies primarily comprised of a valve body, a cover, an actuating motor, a position sensor, and a transition gear on a gear shaft. With respect to origin, the throttle body is assembled in Thailand using a valve body from Thailand, a software chip from Germany and other components primarily sourced from China. The final assembly begins by manually installing a shaft seal onto the valve body. Next, one to two bearings and a transition gear shaft are press-fit into position, followed by the installation of a torsion spring. The throttle shaft assembly is then loaded, twisted, and pressed into position. Subsequently, a shaft collar is punched onto the base of the valve body. The throttle plate, socket assembly, motor assembly, German-manufactured chip, and Chinese-manufactured sensor assembly are then installed in sequence. The process finishes with the tightening of screws, the soldering of motor terminals, and final programming. For item number E57C, additional steps occur. Such steps include the manual application of lubricating oil on the seal ring, followed by the installation of a side cover and a crimp plug. Testing and inspections are conducted throughout the assembly process. 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). In this instance, components such as the motor assembly, the throttle plate, and the gearing are press-fit or manually inserted into the valve body. This process is relatively simple and does not transform the Chinese components into new and different articles of commerce with a name, character, and use distinct from those possessed prior to assembly. Because these processes do not result in a substantial transformation, we rely on the origin of the valve body to determine the origin of the subject throttle bodies. The valve body is bulky, accounts for a significant portion of the unit, and is fundamental to the air-regulating process. Based on these factors, it is the essential component of the throttle bodies. Consequently, as the country of origin for both valve bodies is Thailand, the country of origin of the throttle body models 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 Sandra Martinez at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division