OT:RR:NC:N2:201
Jian Zhang
DEPU Tech Co., LTD
Tambon Khaokansong, Si Racha District, Chon Buri
Si Racha 20110
Thailand
RE: The country of origin of ignition coils for an automotive engine
Dear Mr. Zhang:
In your letter dated March 26, 2025, you requested a country of origin ruling on ignition coils.
In your request, you state that the ignition coils are fully produced and assembled in Thailand. The raw
materials are either of Chinese or Thai origin. You presented documents/slides and a video showing the
production work done in Thailand.
The first item under consideration has been identified as an ignition coil, part # KD-9003. The ignition coil is
a crucial component in a vehicle's ignition system. Its primary function is to convert the low voltage from the
car's battery into the high voltage needed to create a spark in the spark plugs. This spark ignites the air-fuel
mixture in the engine cylinders, enabling the engine to run. This product incorporates plastic housing, copper
wire, plastic skeleton, iron core, module, and rubber boot.
You state that the procedure for producing part # KD-9003 is the following:
Primary connector is used to connect the ignition coil primary and wiring harness to ECU. Origin
Thailand, incorporated into ignition coil in Thailand
The primary spool is mainly used to support and fix the primary coil, ensuring its stable operation in
low voltage environments. Origin Thailand, incorporated into ignition coil in Thailand
The secondary spool is used to support and fix the secondary coil, ensuring its stable operation under
high temperature and high voltage environments. Origin Thailand, incorporated into ignition coil in
Thailand
Primary enameled wires are used to conduct low voltage currents and generate magnetic fields, storing
energy. Origin China, wrapped on primary spool in Thailand
Secondary enameled wire is used to induce high voltage at the output end of the secondary coil when
the magnetic field generated by the primary coil current changes, generating sparks in the spark plug
gap and igniting the air-fuel mixture. Origin China, wrapped on secondary spool in Thailand
The main function of the iron core is to enhance the magnetic field and ensure voltage conversion
efficiency. Origin China, processed and incorporated into ignition coil in Thailand
The function of the housing is to protect internal components and provide external insulation, ensuring
the normal operation of the ignition coil. Origin Thailand, incorporated into ignition coil in
Thailand
The high-voltage boot is mainly used to protect the high-voltage output part from external
environmental influences, provide insulation to the external parts, and ensure the safety and reliability
of the ignition system. Origin China, incorporated into ignition coil in Thailand
Epoxy resin is used to encapsulate and protect internal components from external impacts and provide
insulation for internal and external components to ensure the normal operation of the coil. Origin
China, incorporated into ignition coil in Thailand
The second item under consideration has been identified as an ignition coil, part # KD-9021, which is used to
provide electrical energy to the spark plugs. This product incorporates a plastic housing, copper wire, plastic
skeleton, iron core, module, and rubber boot.
You state that the procedure for producing part # KD-9021 is the following:
Primary connector is used to connect the ignition coil primary and wiring harness to ECU. Origin
Thailand, incorporated into ignition coil in Thailand
The primary spool is mainly used to support and fix the primary coil, ensuring its stable operation in
low voltage environments. Origin Thailand, incorporated into ignition coil in Thailand
The secondary spool is used to support and fix the secondary coil, ensuring its stable operation under
high temperature and high voltage environments. Origin Thailand, incorporated into ignition coil in
Thailand
Primary enameled wires are used to conduct low voltage currents and generate magnetic fields, storing
energy. Origin China, wrapped on primary spool in Thailand
Secondary enameled wire is used to induce high voltage at the output end of the secondary coil when
the magnetic field generated by the primary coil current changes, generating sparks in the spark plug
gap and igniting the air-fuel mixture. Origin China, wrapped on secondary spool in Thailand
The main function of the iron core is to enhance the magnetic field and ensure voltage conversion
efficiency. Origin China, processed and incorporated into ignition coil in Thailand
The function of the housing is to protect internal components and provide external insulation, ensuring
the normal operation of the ignition coil. Origin Thailand, incorporated into ignition coil in
Thailand
The high-voltage boot is mainly used to protect the high-voltage output part from external
environmental influences, provide insulation to the external parts, and ensure the safety and reliability
of the ignition system. Origin China, incorporated into ignition coil in Thailand
Epoxy resin is used to encapsulate and protect internal components from external impacts and provide
insulation for internal and external components to ensure the normal operation of the coil. Origin
China, incorporated into ignition coil in Thailand
When determining the country of origin for purposes of applying current trade remedies under Section 301,
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).
With the facts and documentation presented, it is the opinion of this office that the ignition coils, part #
KD-9003 and KD-9021 are substantially transformed during the manufacturing process in Thailand and thus
that the country of origin of the complete Ignition Coil for an automotive engine 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 Matthew Sullivan at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division