OT:RR:NC:N2:212
Long Chen
Thai Jiuzhou Electron CO LTD
88/152 Moo 15 Bangsaotong Sub-District
Bangsaotong 10540
Thailand
RE: The country of origin of cooktop switch harnesses
Dear Mr. Chen:
In your letter dated June 30, 2025, you requested a country of origin ruling.
The merchandise under consideration is described as a switch harness for use in a gas range and identified by
the following part numbers; 164D9790GXXX, 191D9236GXXX, 301D2124GXXX, 301D2125GXXX,
301D2126XXX, and 311D5137GXXX. We note that the different variations are virtually identical and only
differ by the specific appliance with which they will be used. The subject device is comprised of a set of
insulated cable conductors with multiple compression switches attached as well as an electrical connector at
the end. You state that the subject switch harness is used as a component in a gas range in order to act as the
ignition trigger for the cooktop.
In your request, you state that the insulated wire harness and switch components are made in China and
shipped to Thailand for assembly. In Thailand, the wire harness is placed within the switch base before the
remainder of the switch parts, including the contacts and cam button, are assembled on top of the base. The
switch cover is then placed over the assemblies and the finished harness is tested and packaged for shipment
to the U.S.
When determining the country of origin for purposes of applying current trade remedies under Section 301
and 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).
Regarding the origin of subject switch harness, it is the opinion of this office that the insulated wire as well as
the switch components impart the character of the device. Further, the assembly procedures performed in
Thailand are simple in nature and do not substantially transform the Chinese components into new and
different articles of commerce. Base upon the facts presented, the country of origin of the switch harness, part
numbers 164D9790GXXX, 191D9236GXXX, 301D2124GXXX, 301D2125GXXX, 301D2126XXX, and
311D5137GXXX, will be China.
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 Luke LePage at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division