The country of origin of an automotive power window switch assembly

N363896August 12, 2026OT:RR:NC:N2:220
CATEGORY: OriginShurong ZengSitronic Automotive Technology Co., Ltd.168/14 Moo.3 Map Kha, Nikhom PhatthanaRayong 21180ThailandRE: The country of origin of an automotive power window switch assemblyDear Ms. Zeng:In your letter dated
July 31, 2026
, you requested a country of origin ruling.The merchandise under consideration is an automotive power window switch assembly, Model Number2073, which is a driver’s side multi-function switch assembly. The power window switch assembly isinstalled in the driver’s door of a vehicle for the purpose of adjusting the viewing angle of a vehicle’sside-view mirrors, folding or unfolding a vehicle’s side-view mirrors and raising, lowering, or locking thevehicle’s windows.You state that the manufacturing process begins in Thailand with the production of a printed circuit boardassembly (PCBA). In Thailand, electronic components such as capacitors, resistors, diodes, microchips,relays, and switches are assembled onto a bare printed circuit board via surface mount technology (SMT). InThailand, with components sourced from China and Thailand, the PCBA is further assembled into a plastichousing with other switch components including a conductive rubber pad, connector pin, light guides, plasticsupport brackets, cover plates, switch covers, and decorative trim to make a complete power window switchassembly. The finished assembly is inspected, tested, and packaged for export to the United States.When determining the country of origin for purposes of applying current trade remedies under Section 301and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters RulingLetter H301619, dated November 6, 2018. The test for determining whether a substantial transformation willoccur is whether an article emerges from a process with a new name, character, or use different from thatpossessed 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 unlessexcepted, 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 amanner 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 beable to know by an inspection of the marking on the imported goods the country of which the goods is theproduct. 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 shouldinfluence 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 thecountry of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBPRegulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, orgrowth of any article of foreign origin entering the United States. Further work or material added to an articlein another country must effect a substantial transformation in order to render such other country the “countryof origin” within the meaning of the marking laws and regulations.Regarding the country of origin of the , in our view the assemblyautomotive power window switch assemblyof the PCBA in T by soldering the individual components onto the bare board results in a substantialhailandtransformation of the individual components to produce a PCBA of T origin. Fuhairthermore, it is the opinionCBA establishes the function of the switchof this office that the P automotive power window assemblybecause it is the article within the assembly that opens and closes the electrical circuit and provides the function. As such, we find that the individual components that make up the aelectrical controlutomotive switch are transformed in Tinto a new article of commerce with a differentpower windowassemblyhailand name, character, and use. Thus, the automotive power window switch assembly, Model Number 2073i sconsidered product of T for origin and marking purposes at time of importation into the United ahailandStates.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 Gary Chaffee at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division