OT:RR:NC:N2:206
Nora Zeng
Vietnam Four Season Machinery Manufactory Company Limited
Lot CN3D, Deep C 2B Industrial Park, Dinh Vu - Cat Hai Economic Zone
Hai Phong 180000
Vietnam
RE: The country of origin of window regulators
Dear Ms. Zeng:
In your letter dated January 16, 2026, you requested a country of origin ruling on window regulators.
The articles under consideration are window regulators, Part Numbers 4030LT, 4061LT, 4162KT, and
4771LT, which are used in passenger vehicles. You state that a window regulator is a critical component
located in the vehicle door that controls the movement of the window glass. It transforms the rotational force
generated by an electric motor into linear motion, allowing the window to be raised and lowered smoothly.
This mechanism ensures convenient and reliable operation of power windows in modern automobiles. The
window adjustment system begins by receiving a signal from the power window switch, which is then
transmitted to the power window motor, activating the window regulator. This mechanism subsequently
transfers power to the regulator handle, allowing the window glass to move up or down following the
passenger's control. The key components of a window regulator are guide rail, cables and related
components, and a window lift motor.
Part Numbers 4030LT, 4061LT, 4162KT, and 4771LT are window regulators without a motor. The guide
rails with its supports and brackets, steel cable assemblies, and motor mounting brackets are produced in
Vietnam from locally sourced galvanized steel sheet plates. These sheets undergo cutting, stretch forming,
hole flaring, trimming, and electric welding and riveting to create these components. Other components, such
as pulleys, sleeves, coils, and other minor parts are made in China and imported into Vietnam for final
assembly.
Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every
article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly,
indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to
indicate to the ultimate purchaser in the United States, the English name of the country of origin of the
article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to
know by an inspection of the marking on the imported goods the country of which the goods is the product.
The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by
knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should
influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940).
Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the
country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP
Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or
growth of any article of foreign origin entering the United States. Further work or material added to an article
in another country must effect a substantial transformation in order to render such other country the “country
of origin” within the meaning of the marking laws and regulations.
A substantial transformation occurs when, as a result of manufacturing process, a new and different article
emerges, having a distinct name, character or use, which is different from that originally possessed by the
article or material before being subjected to the manufacturing process. See United States v.
Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940).
In the present case, most major components of the window regulator are made in Vietnam. The Chinese
components when joined with the Vietnamese made guide rails and cables lose their individual identities and
become parts of the whole unit. As a result, it is the opinion of this office that a substantial transformation
occurs in Vietnam and the country of origin of the window regulators, Part Numbers 4030LT, 4061LT,
4162KT, and 4771LT, will be Vietnam for marking purposes.
You also requested that we make a country of origin determination on window regulators, Part Numbers
4030L, 4061L, 4162K, and 4771L, each of which contains a window lift motor. However, your inquiry does
not provide enough information for us to give a proper country of origin analysis for these articles. Your
request for a country of origin ruling should include the name and address of the lift motor’s manufacturer,
pictorial diagrams or videos of the motor at each state of production, and the bill of materials (BOM) for the
lift motor. When this information is available, you may wish to consider resubmission of your request. We
are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of
the material that we have returned to you. Additionally, please include a statement as to whether there are, to
your knowledge, any issues on the commodity pending before Customs or any court. Also include a
statement as to whether classification advice has been sought from a Customs officer; and if so, from whom,
and what advice was rendered, if any.
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,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division