OT:RR:NC:N2:201
Shengrong Zhang
Zhuoye Automotive Technology (Thailand) Co., LTD.
168/13, Moo 3, MapKha Subdistrict, Nikhom Phatthana District, Rayong Province
Nikhom Phatthana 21180
Thailand
RE: The country of origin of ignition coils for an automotive engine
Dear Mr. Zhang:
In your letter dated April 21, 2026, you requested a country of origin ruling on ignition coils for automotive
engines.
An ignition coil acts as an induction coil that transforms the low voltage (12v) from a car battery into the
high voltage (thousands of volts) needed to operate spark plugs. This intense pulse of energy arcs across the
spark plug gap, igniting the air-fuel mixture to power the engine.
You state that these ignition coils are designed for modern passenger vehicles, such as the Toyota Camry,
BMW 3 Series, Ford F-150, Volkswagen Golf, and others.
In your request, you state that the ignition coils are assembled in Thailand, consisting of raw materials
sourced from Thailand and China. You provided a Bill of Materials (BOM), along with production process
documents, schematic diagrams, illustrations, and a manufacturing line mp4 video/YouTube showing the
production work done in Thailand.
The production steps shown in your assembly process diagrams from Thailand include:
Primary winding - Install the primary skeleton into the fixture
Secondary skeleton insertion piece - Insert the secondary plug into the corresponding hole
Secondary winding - Install the secondary skeleton into the fixture
Secondary soldering, installing connection pins - Tin the secondary coil that has been wound on the
two plugs to make the secondary wire conductive with the plugs, and install it into the connecting pins
Primary winding tape - Install the primary skeleton into the fixture, adhere the polyurethane tape
tightly
Assembly of primary and secondary coils - After installing the T-shaped iron core and magnetic plates
into the primary coil assembly, install the primary coil into the secondary coil
Assembly of iron core and partition - After assembling the C-type iron core with the partition, install
the coil assembly into it
Install the coil assembly into the casing - Use a pneumatic press to press the coil assembly into the
housing and install it in place
Install the ignition module into the casing - Install the ignition module into the casing, twist the wires
and solder them
Semi-finished product testing - Connect and test the semi-finished products
Potting - Preheat the tested semi-finished products on the tray, vacuum glue them, and cure them
Attachment assembly - Assemble the high-pressure rod components and springs of the glued product
Open test - Perform a half minute open circuit test on the finished product
Finished Product Testing - Conduct finished product testing on products with good road conditions
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).
With the facts and documentation presented, it is the opinion of this office that the ignition coils components
and subassemblies are substantially transformed during the manufacturing process in Thailand. Thus, the
country of origin of the complete automotive engine ignition coils is Thailand for marking purposes.
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 Matthew Sullivan at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division