OT:RR:NC:N2:212
Samantha Hayward
International Custom Services Inc.
N64W24801 Main St, Suite 121
Sussex, WI 53089
RE: The country of origin of speed sensor assemblies
Dear Ms. Hayward:
In your letter dated August 21, 2025, you requested a country of origin ruling on behalf of your client, TMI
EP, LLC.
The items under consideration are identified by part numbers 20100321, 20100328, 20100332, and 20100105
and described as automotive Speed Sensor Assemblies. These devices are comprised of a Hall Effect
integrated circuit (IC) which is attached to a signal pathway and protection PCBA within a plastic enclosure
with a connector at one end. The subject devices are used in various applications, such as vehicles, to detect
the speed and position of various mechanical components. The devices function as a transducer by creating a
magnetic field that, when broken by the presence of a metal object (i.e. the engine part), creates an electrical
signal that is then sent to an external control unit for processing.
In your request, it is stated that the manufacturing process begins with the creation of the Hall Effect IC in the
Philippines, which includes the silicon microchip and the magnet assembly. This finished IC is then sent to
China where it is soldered to the PCBA and placed within the plastic carrier enclosure, which incorporates
the electrical connector. We note that the PCBA is manufactured in China with various resistors, diodes, and
capacitors. This component functions as the sensor pathway and provides circuit protection. The remaining
plastic parts are then assembled around the sensor and the finished device is inspected and packaged for
shipment to the U.S.
When determining the country of origin for purposes of applying current trade remedies under Section
301and 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 the subject speed sensors, it is the opinion of this office that the Hall Effect IC
imparts the character of the finished device. This IC provides the essential functions of the device as it
creates the magnetic and electrical signal, which is the component that senses the appropriate speed. Further,
the assembly process performed in China is simple in nature and would not result in a substantial
transformation of the individual components into new and different articles of commerce. Based on the facts
presented, the country of origin of the Speed Sensor Assemblies, item numbers 20100321, 20100328,
20100332, and 20100105 will be the Philippines.
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)
Denise Faingar
Acting Director
National Commodity Specialist Division