OT:RR:NC:N2:212
Friederike Görgens
Greenberg Traurig, LLP
2101 L Street N.W.
Washington, DC 20037
RE: The country of origin of an oil immersed transformer
Dear Mr. Görgens:
In your letter dated November 20, 2025, you requested a country of origin ruling on behalf of your client,
Eaglerise Electric & Electronic Company, Ltd.
The merchandise under consideration is identified by model number ZGSL-G-4400/34.5 and described as a
standard oil immersed transformer. The subject device is comprised of two coils, the primary and secondary,
wound around an iron core that is immersed in insulating oil. The transformer is designed to allow electrical
flow from the primary coil, through the iron core, which induces a current change, to the secondary coil. The
device functions as a step-up transformer, in that it increases voltage, within various power generation and
energy storage systems. You state that the transformer has a maximum capacity of 11200kVA
(kilovolt-amperes).
In your request, you state that the manufacturing process occurs in Thailand using primarily Chinese
components. The process begins with the winding of Chinese wire in the appropriate configuration around
the iron core, which originates in Thailand. This creates the primary coil, secondary coil, and the magnetic
core. The core and coils are then placed within the tank, which originates from Thailand, and electrical
connections are made using various Chinese components. The tank is then filled with oil from India before
the finished transformer is tested for function 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 the subject transformer, it is the opinion of this office that the electrical function of
the device is imparted by the flow of electricity through the core and coils. As such, each component is of
equal importance. In our view, the winding of the Chinese wires into the coils is not significantly complex.
However, the totality of the assembly operations performed in Thailand establish the essential electrical
functions of the device. Therefore, based on the facts presented, the country of origin of the oil immersed
transformer, model number ZGSL-G-4400/34.5, will be 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 Luke LePage at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division