RE: The country of origin of an automotive headlight switch assembly

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 N365444 October 6, 2026 OT:RR:NC:N2:220 CATEGORY: Origin Ms. Shurong Zeng Sitronic Automotive Technology Co., Ltd 168/14 Moo.3 Map Kha, Nikhom Phatthana Rayong 21180 Thailand RE: The country of origin of an automotive headlight switch assembly Dear Ms. Zeng: In your letter dated September 27, 2026, you requested a country of origin ruling. The item under consideration in this request is an automotive headlight switch assembly, model number KD-2002, which is a multi-function switch assembly used to control a vehicle’s headlights and instrument illumination intensity level. The automotive headlight switch assembly is installed in close proximity to the driver’s seating position in a vehicle for the purpose of adjusting the vehicle’s instrument panel illumination intensity level and selecting the exterior lighting such as headlights OFF, headlights ON, headlights AUTO ON/OFF, and parking lamps only ON. In Thailand, electronic components such as resistors, diodes, and LEDs are assembled onto a bare printed circuit board via surface mount technology (SMT). In Thailand, with components sourced from China and Thailand, the PCBA is further assembled into a plastic housing with other switch components including electrical contacts, springs, and mechanical components such as a Rotary Knob and Rotary Wiper Contacts to make a complete automotive headlight switch assembly. 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 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, 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 a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. 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 should influence 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 the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Regarding the country of origin of the automotive headlight switch assembly, in our view the assembly of the PCBA in Thailand by soldering the individual components onto the bare board results in a substantial transformation of the individual components to produce a PCBA of Thai origin. Furthermore, it is the opinion of this office that the PCBA establishes the function of the automotive headlight switch assembly because it is the article within the assembly that opens and closes the electrical circuit and provides the electrical control function. As such, we find that the individual components that make up the automotive headlight switch assembly are transformed in Thailand into a new article of commerce with a different name, character, and use. Thus, the automotive headlight switch assembly, model number KD-2002 is considered a product of Thailand for origin and marking purposes at time of importation into the United States. 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