OT:RR:NC:N1:102
Xiaozhen Qiao
Joinhands Injection System (Thailand) Co., Ltd
890 / 25 Moo 3, Khao Khan Song Subdistrict
Si Racha District, Chonburi Province 20110
Thailand
RE: The country of origin of a fuel injector
Dear Ms. Qiao:
In your letter dated February 21, 2025, you requested a country of origin ruling for a fuel injector.
Descriptive information was included in the submission.
The product in question is referred to as a fuel injector. The fuel injector is a solenoid valve that consists of a
body that primarily encases a ball valve, a valve seat, an orifice plate, and a spring. The solenoid valve
controls the flow of fuel into the fuel supply system of a motor vehicle. The injector is designed to connect to
a fuel rail and an intake manifold.
Concerning the origin of the fuel injector, you state that it will be assembled in Thailand from components
that originate in Japan, Thailand, and China.
The following processes occur in Thailand prior to the final assembly. A hole is drilled into the circular
shaped plate to create a plate with an orifice. Less than five percent of material is removed. To produce the
solenoid actuator, pins manufactured in China are connected to wires and inserted into a Thai-manufactured
bobbin. The necessary winding process occurs. The components are then welded in place. To produce a valve
subassembly, a ball of Japanese origin is welded to a Thai-manufactured armature. The ball is then subjected
to a grinding process. Afterward, a filter, which is of Chinese origin, is positioned in place.
The final assembly process begins with the installation of a Thai magnetic ring and a Chinese adjust tube into
a core produced in Thailand. Then, an inlet tube, a non-magnetic tube and a guide tube, all from Thailand, are
connected and welded to the core. Next, a solenoid, along with a magnetic cap and ring, which are both
manufactured in Thailand, are installed to the core and welded in place. A plastic piece produced in Thailand
is placed over the solenoid. Afterwards, an orifice plate is welded to a Thai-manufactured valve seat and
these connected components are installed into the housing. Additional components are then installed into the
housing, which includes the valve subassembly and a Chinese spring. Once these components are adjusted,
they are welded into position. Upon completion, the finished fuel injector undergoes various testing.
When determining the country of origin, 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 from Japan, China and Thailand are assembled together in Thailand to form
subassemblies that are affixed to additional components from China and Thailand to produce a fuel injector.
When considering the totality of the circumstances of the fuel injector, this office finds that the
manufacturing of the valve body, along with the assembly processes that join a Thai-produced solenoid and
the valve subassembly to the body, in Thailand, taken as a whole, are sufficiently complex and meaningful as
to result in a substantial transformation, such that the non-originating components lose their individual
identities and become an integral part of a new article, possessing a new name, character and use. Based on
the manufacturing and assembly processes described in the submission, we find that the country of origin of
the fuel injector 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,
Steven A. Mack
Director
National Commodity Specialist Division