OT:RR:NC:N2:212
Samantha Hayward
International Custom Services, Inc.
P. O. Box 339
Pewaukee, WI 53072
RE: The country of origin of speed sensor assemblies
Dear Ms. Hayward:
In your letter dated January 19, 2026, you requested a country of origin ruling on behalf of your client, TMI
EP, LLC.
The merchandise under consideration is described as five models of a speed sensor assembly, individually
identified by part numbers 15103242, 16107151, 16107158, 16107159, and 16107163. The devices are
comprised of a magnetic sensor Integrated Circuit (IC) within a plastic enclosure and attached to an insulated
cable. In use, the speed sensor is attached within the wheel of a vehicle and acts as a transducer by creating a
magnetic field that, when interrupted by the presence of the wheel, creates an electrical signal that is sent to
the Electronic Control Unit (ECU) for interpretation. This signal is used to determine the speed of the wheel
and is used within the tire monitoring system of the vehicle.
In your request, you state that the manufacture of the finished good begins with the creation of the sensor IC
in Malaysia. This sensor is then sent to China where it is cut and bent to fit within the carrier assembly along
with a magnet of Chinese origin. This creates the sensor head, which is then attached to a Chinese cable and
covered with a plastic mold. The finished sensor is then packaged for shipment to the United States.
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 assemblies, it is the opinion of this office that the speed sensor IC, which
is manufactured in Malaysia imparts the critical function of this device. The assembly process that takes
place in China is simple in nature and would not effect a substantial transformation of the speed sensors.
Based on the facts presented for the speed sensor assembly, part numbers 15103242, 16107151, 16107158,
16107159, and 16107163, the country of origin will be Malaysia.
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
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division