OT:RR:NC:N2:206
Eun Hyung Bu
Webasto Korea
6, Cheoyongsanup-ro, Onsan-eup, Ulju-gun
Ulsan, 44993
South Korea
RE: The country of origin of panoramic sunroof assemblies
Dear Ms. Bu:
In your letter dated April 24, 2025, you requested a country of origin ruling on panoramic sunroof
assemblies.
The articles under consideration are panoramic sunroof assemblies, Panorama Sunroof NX4 (Model
7611640A) and Sunroof Assembly NX4a MMH (Model 7612134A), which are used in passenger vehicles.
Each sunroof covers the entire roof of a vehicle and allows for ventilation and light control by tilting and
sliding the roof panel. They are installed in vehicles to provide natural light and a sense of openness.
Compared to a standard sunroof, the panoramic sunroofs offer superior openness, contributing to the
vehicle’s exterior design. They are mainly installed in high-end trims or SUVs, and consist of various
components, such as a glass panel, roller blind assembly, frame, motor, and mechanism that work together in
coordination.
To slide open, each sunroof operates using a motor-driven sliding mechanism that moves them forward and
backward. The user can open and close each sunroof through a switch located inside the vehicle, and the
motor either pulls the glass panel forward or pushes it backward to open or close the sunroof.
You state that Model 7611640A consists of a tempered glass/infrared-blocking glass from China, and
frame/rails (aluminum alloy and high-strength plastic), sealing components (rubber), and a motor from South
Korea. The glass from China is shipped to South Korea where it undergoes an assembly process with the rest
of the Korean components. The assembly process includes polyurethane (PU) encapsulation, inserting
components into one another, fitting and assembling by screws or otherwise attaching, and oiling and
greasing the components.
Model 7612134A consists of a tempered glass/infrared-blocking glass, frame/rail components, and sealing
components from South Korea, and a motor from the Philippines. The motor is shipped to South Korea to be
assembled with the rest of the Korean components. The assembly process is similar to the process described
above for Model 7611640A.
When determining the country of origin, 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).
In the present case, the components to make the sunroof assemblies are complete and no substantial
transformation occurs in South Korea. You assert that the PU encapsulation is a complex process that results
in a substantial transformation of the components. We disagree. You describe this process as a technology
that makes the glass an integrated frame, allowing it to be easily attached to the body without adhesives or
clips. However, the glass itself does not undergo any change, and the integrity of the glass remains the same.
The processes performed in South Korea do not transform the glass into a new article, as the end-use of the
glass is pre-determined. Since the glass is the main component of the sunroof assembly and the rest of the
components are ancillary, the country of origin of the sunroof assembly will be the country of origin of the
glass. As a result, it is the opinion of this office that the country of origin for Model 7611640A will be China
and the country of origin for Model 7612134A will be South Korea.
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 Liana Alvarez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division