CLA-2-85:OT:RR:NC:N4: 410
Long Chen
Thai Jiuzhou Electron Co Ltd.
88/152 Moo 15 Bangsaotong Sub-District
Bangsaotong 10540
Thailand
RE: The eligibility under the United States-Mexico-Canada Agreement (USMCA) of oven latch assemblies
from Mexico and China
Dear Mr. Chen:
In your letter dated July 8, 2025, you requested a binding ruling on the eligibility of oven latch assemblies
under the United States-Mexico-Canada Agreement (USMCA). The oven latch assemblies are identified as
parts 311D6081P001 and 191D7106P007. The oven latch assemblies each consist of nine components as
below listed:
Latch
Pin
Rod
Power driver containing an electric motor
Screw
Metal bracket 1
Metal bracket 2
Metal bracket 3
Metal bracket 4
FACTS:
You indicated in your submission that these latch assemblies are parts of gas-electric ranges for domestic use.
The gas-electric ranges are classified in subheading 8516.60.4082, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for cooking stoves, ranges and ovens, other, of a maximum width exceeding
70 centimeters: containing a radiant heated cooktop. The subject latch assemblies are classified in subheading
8516.90.8050, HTSUS, as parts for the cooking stoves, ranges and ovens of subheading 8516.60.40: other,
other.
In your request, you present four manufacturing scenarios, in which the oven latch assemblies are fabricated
with components of both Chinese-origin and Mexican-origin. In Scenarios 1, 2 and 4, the factory in Mexico
will produce certain components from China and assemble them with the Mexican-origin components to
make the finished oven latch assemblies. In Scenario 3, the Mexican-origin component will be shipped to
China and the factory in China will assemble the Mexican-origin component with the Chinese-origin
components to make the finished products.
In Scenario 1, all components are made in Mexico except for the pin, rod, and power driver, which are
imported from China. In Scenario 2, all components are imported from China except for the power driver,
which is produced in Mexico. Scenario 3 is the same as Scenario 2 except that the final assembly will be in
China instead of Mexico. Scenario 4 is the same as Scenario 1 except the power driver is made in Mexico
and the screw is imported from China.
USMCA:
The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30,
2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the
USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. ยง 4511(a)). General Note ("GN")
11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is
an originating good for purposes of the USMCA. GN 11(b) states:
For the purposes of this note, a good imported into the customs territory of the United States from the
territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential
tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the
tariff schedule as a "good originating in the territory of a USMCA country" only if-
(i) the good is a good wholly obtained or produced entirely in the territory of one or more
USMCA countries;
(ii) the good is a good produced entirely in the territory of one or more USMCA countries,
exclusively from originating materials;
(iii) the good is a good produced entirely in the territory of one or more USMCA countries
using non-originating materials, if the good satisfies all applicable requirements set forth in
this note (including the provisions of subdivision (o));
Since the latch assemblies contain non-originating materials, they are not considered a good wholly obtained
or produced entirely in a USMCA country under GN 11(b)(i), nor are the products produced exclusively from
originating materials per GN 11(b)(ii). Thus, we must determine whether the product qualifies under GN
11(b)(iii). The latch assemblies are classified under subheading 8516.90, HTSUS. The applicable rule of
origin for goods classified under subheading 8516.90, HTSUS, is in GN 11(o)/ Chapter 85, HTSUS, which
provides, in relevant part:
46. (A) A change to subheading 8516.90 from any other heading;
Based on the facts provided, the goods described above qualify for USMCA preferential tariff treatment,
because they meet the requirements of General Note 11(b)(iii) since all non-originating components and
materials undergo the prescribed tariff shift. The goods will, therefore, be entitled to a free rate of duty under
the USMCA upon compliance with all applicable laws, regulations, and agreements.
HOLDING:
The oven latch assemblies, in manufacturing scenarios 1, 2 and 4 described above, qualify for USMCA upon
compliance with all applicable laws, regulations, and agreements. However, because the final assembly for
Scenario 3 is in China, and the oven latch assemblies are exported from China, the oven latch assemblies in
Scenario 3 do not qualify for USMCA.
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 Michael Chen at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division