OT:RR:NC:N1:105
Ryan Supek
TE Connectivity Corporation
2800 Fulling Mill Road
Middletown, PA 17057
RE: The country of origin of pressure sensors
Dear Mr. Supek:
In your letter dated January 28, 2026, you requested a country of origin ruling on pressure sensors.
Descriptive literature was provided for our review.
This ruling addresses four distinct models of pressure sensors, identified by part numbers 20005327-42,
11026687-00, 4525-DS5A001GP, and 20008088-03.
The 20005327-42 Pressure Sensor is a piezoresistive strain gauge sensor encased in a stainless-steel housing.
This product is designed for industrial and commercial Original Equipment Manufacturers (OEMs) engaged
in small to high-volume semiconductor manufacturing equipment. The stainless-steel packaging renders the
sensor compatible with both gas and liquid media, enabling it to measure the volume of these substances
within semiconductor manufacturing equipment chambers. The sensing package functions by transferring
pressure from a stainless-steel diaphragm to the internal sensing element.
The 11026687-00 Pressure Transducer is also a piezoresistive strain gauge pressure sensor, similarly
packaged in a stainless-steel housing. It is intended for industrial and commercial manufacturers across a
range of small to high-volume applications. The stainless-steel encapsulation ensures its compatibility with
gas and liquid media.
The 4525-DS5A001GP Pressure Transducer is engineered for pressure measurement in OEM applications. It
is manufactured utilizing a proprietary UltraStable process, which guarantees long-term stability and
reliability. This transducer incorporates advanced complementary metal-oxide-semiconductor (CMOS)
sensor conditioning circuitry to deliver high performance at a competitive cost. Employing
micro-electro-mechanical systems (MEMS)-based piezoresistive sensing technology, it converts applied
pressure into an electrical signal. The sensing element is mounted on a ceramic substrate and protected by a
ceramic cover. The signal is subsequently processed and calibrated by an Application-Specific Integrated
Circuit (ASIC). This device is available in multiple configurations, including side port, top port, and manifold
mount, to accommodate diverse installation requirements.
Finally, the 20008088-03 Pressure Sensor is specifically designed for use in medical instruments, factory
automation systems, and leakage detection applications. It employs MEMS-based piezoresistive sensing
technology to convert applied pressure into an electrical signal. The assembly comprises a MEMS chip
(sensing die) mounted on a header and secured with adhesive. Electrical connection is established via
integrated pins, which transmit the converted voltage signal.
Each pressure sensor has its own unique (but similar) manufacturing process as outlined below.
The manufacturing process for the 20005327-42 Pressure Sensor starts with the sensing gauge, fabricated in
wafer form, being produced at a wafer manufacturing facility in Germany. The wafer undergoes etching,
processing, and qualification to ensure adherence to all required performance specifications. At this stage, the
die within the wafer is capable of sensing pressure and providing an electrical output when probed. Upon
completion, the wafer is transported to China for subsequent assembly. In China, the wafer is diced into
individual gauges in preparation for assembly. The housing (port) is subjected to surface sanding and plasma
cleaning prior to the bonding of the gauges with a glass paste adhesive. This assembly is then fired and
glazed, permanently securing the gauges to the port. Electrical connections are established via wire bonding
between the gauges and the printed circuit board assembly (PCBA), followed by a visual inspection to verify
proper placement and bonding integrity. Subsequently, the middle sensor housing (HEX), bracket, and
functional PCBA are integrated into the sensor assembly through soldering and welding processes. The part
number and serial number are then laser-marked onto the HEX. The subassembly undergoes calibration and
functional testing to confirm performance specifications. Following calibration, a connection module is
produced by soldering a connector to a flexible printed circuit board (FPCB), which is then housed and
secured with epoxy. This module is integrated with the subassembly by soldering the FPCB between the two
modules, and the entire product is sealed using laser welding. Finally, the completed sensor module
undergoes insulation and functional testing at room temperature before being packaged for shipment.
The manufacturing process for the 11026687-00 Pressure Transducer begins with the sensing die, produced
in wafer form, which is manufactured at a wafer fabrication facility in the United States. It undergoes
etching, processing, and qualification to ensure compliance with all required performance specifications. At
this stage, the die within the wafer is capable of sensing pressure and providing an electrical output when
probed. Upon completion, the wafer is shipped to China for the remaining manufacturing steps. In China, the
wafer is diced into individual dies. Each die is assembled into a capsule, followed by a visual inspection. The
capsule assembly is then welded to the fitting. After a subsequent visual check, a flexible printed circuit
board (FPCB) is wire bonded to the top of the capsule to enable electrical signal connection. A further
inspection verifies the integrity of this connection. Next, a sensor housing (HEX), bracket, and functional
PCBA are integrated into the sensor assembly through soldering and welding. The part number and serial
number are then laser-marked onto the HEX. The subassembly undergoes calibration and functional testing
to confirm performance. Following calibration, a connection module is produced by soldering a connector to
an FPCB, which is then housed and secured with epoxy. This module is integrated with the subassembly by
soldering the FPCB between the two modules, and the entire product is sealed using laser welding. Finally,
the completed sensor undergoes insulation and functional testing at room temperature before being packaged
for shipment.
The manufacturing process for the 4525-DS5A001GP Pressure Transducer starts with the sensing die,
produced in wafer form, being fabricated at a wafer manufacturing facility in the United Kingdom. The
wafers are etched, processed, and qualified to ensure they meet the desired performance characteristics. At
this stage, the die within the wafer can sense pressure and provide an electrical output when probed. The
wafers are then shipped to China, where the remaining manufacturing process occurs. Upon arrival in China,
the wafers are diced into individual dies in preparation for assembly. The die is mounted onto the substrate,
followed by wire bonding to establish electrical connections between the die, the ASIC, and the substrate
pads. Subsequently, the top lid is affixed to the substrate using epoxy, providing protection for the die and
wire bonds. A lower lid is then attached with epoxy to secure internal components, relieve mechanical stress,
and ensure environmental sealing. The assembly then undergoes a laser marking process, which is a
calibration step involving the application of laser energy to fine-tune the electrical characteristics of the
sensor die or related components to meet exact performance parameters. Following laser marking, the
assembly undergoes adhesive curing and cleaning. The completed sensor undergoes functional testing before
being packaged for shipment.
Finally, the manufacturing process for the 20008088-03 Pressure Sensor starts with the sensing die, produced
in wafer form, in a wafer fabrication facility in the United States. The wafers are etched, processed, and
qualified to ensure they meet the desired performance characteristics. At this stage, the die within the wafer is
capable of sensing pressure and providing an electrical output when probed. The wafers are then shipped to
China, where the remaining manufacturing process occurs. Upon arrival in China, the wafers are diced into
individual dies in preparation for assembly. The assembly process commences with verifying the presence of
all components in the kit. The TO-8 header is then laser-marked with identification, followed by pre-cleaning
and plasma treatment to prepare the surface. The die is subsequently attached to the header with adhesive.
After die attachment, gold wire is utilized to create electrical connections between the die and the header pins
through wire bonding. A subsequent plasma clean is performed, followed by a baking step to cure adhesives
and remove moisture. A visual inspection is conducted to ensure proper die placement and wire bond
integrity. A metal cap is then welded onto the header to seal the die cavity, and a spacer is added. The sealed
sensor assembly then undergoes a temperature coefficient test to characterize its performance over a specified
temperature range. Based on these results, a compensation substrate is matched to the sensor. This substrate
is then individually calibrated using a laser trim process to adjust its circuitry and optimize the sensor’s
overall output accuracy. The completed sensor undergoes final inspection before being packaged for
shipment.
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter (HQ) 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).
Based on the “substantial transformation” principle, which dictates that the country of origin is where an
article emerges from a manufacturing process with a new name, character, or use distinct from its original
form, the origin of the four pressure sensor models is determined by the country where the essential
pressure-sensing component is produced.
For the 20005327-42 Pressure Sensor, the sensing gauge (strain gauge die) manufactured in Germany imparts
the character and functionality of the finished product, as it can independently sense pressure and emit an
electrical output upon leaving Germany. Ancillary components, such as the PCBA and FPCB, serve only to
amplify signals, provide standard output, or facilitate connections, without possessing pressure-sensing
capabilities or installed software. The subsequent assembly operations in China, involving encapsulation,
soldering, gluing, wire bonding, welding, and calibration, are deemed simple assembly and do not result in a
new name, character, or use for the article. Therefore, the country of origin for the 20005327-42 Pressure
Sensor is Germany.
Similarly, for the 11026687-00 Pressure Transducer, the sensing die, produced in the United States, imparts
the character and function of the finished project, capable of independent pressure sensing and electrical
output. The PCBA and FPCB are ancillary, providing signal amplification, electromagnetic compatibility
protection, and connection functions without sensing capabilities or software. The assembly processes in
China, including wire bonding, welding, soldering, sealing, laser marking, calibration, and testing, are
considered simple assembly and do not substantially transform the essential character of the sensing die.
Consequently, the country of origin for the 11026687-00 Pressure Transducer is the United States.
Regarding the 4525-DS5A001GP Pressure Transducer, the sensing die, fabricated in the United Kingdom,
imparts the character and function of the finished sensor, possessing independent strain-sensing and electrical
output capabilities. The ASIC function is limited to calibration, and the substrate’s role is solely for electrical
signal connection; it neither possesses pressure-sensing capabilities nor software. The assembly operations in
China, comprising die mounting, wire bonding, epoxy sealing, curing, cleaning, and laser trim calibration, are
considered simple assembly and do not create an article with a new name, character, or use. Thus, the country
of origin for the 4525-DS5A001GP Pressure Transducer is the United Kingdom.
Finally, for the 20008088-03 Pressure Sensor, the sensing die, manufactured in the United States, imparts the
character and function of the finished product, capable of independent pressure sensing and electrical output.
Ancillary components, such as the compensation substrate, are used for calibration through resistance value
trimming and do not possess pressure-sensing capabilities or software. The assembly operations in China,
which include die attachment, wire bonding, plasma cleaning, baking, welding, laser marking, temperature
coefficient testing, and laser trim calibration, are determined to be simple assembly and do not result in a
substantial transformation of the essential sensing die. Therefore, the country of origin for the 20008088-03
Pressure Sensor is the United States.
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 Jason Christie at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division