OT:RR:NC:N1:105
Kerry Wang
Braumiller Law Group PLLC
5220 Spring Valley Road, Suite 200
Dallas, TX 75254
RE: The country of origin of thermal spray coating machines
Dear Ms. Wang:
In your letter dated May 27, 2026, on behalf of your client, Oerlikon Metco (US) Inc., you requested a
country of origin ruling on thermal spray coating machines. Descriptive literature was provided for our
review.
The items under consideration are described as thermal spray coating machines, which are designed to apply
durable, wear, and corrosion-resistant coatings to substrates using various thermal spray processes, including
plasma spray, high-velocity oxygen fuel (HVOF), and flame spray. Each machine platform consists of two
primary modules, which house internal sub-systems assembled from globally sourced components.
Specifically, the Surface Platform integrates a coating module and a process module, which collectively
provide all necessary components and sub-systems for a complete thermal spray coating operation.
The coating module is engineered to support up to three distinct thermal spray processes. Its core component
can be configured for single or triple cathode plasma spray, HVOF (gas or liquid-fuel), and combustion
powder spray capabilities. The process module contains ancillary components essential for supporting the
coating module’s operation. This module includes a multicoat controller, a process management system, a
power supply, a universal junction and monitoring unit, a gas management system, electrical distribution, a
heat exchanger with two-gun cooling water circuits, and a maintenance access door.
The surface platform thermal spray coating machine integrates components sourced globally, with final
consolidation, electrical integration, calibration, functional testing and assembly occurring in Liechtenstein.
Switzerland is a primary contributor, providing the core process and electronic infrastructure, including the
power control cabinet (PCC), main machine cabinet (MMC) media management units, human machine
interface (HMI) operator panels, interface control cabinets (ICC), SinglePro powder feeder modules, junction
and monitoring assembly (JAM) units, and control unit valve (CUV) media cabinets. From Switzerland also
come ancillary electrical extension modules, power supplies, robotic teaching tools, gas control equipment,
and structural robot mounting pedestals. Furthermore, the heavy mechanical structure of the thermal spray
booth, its acoustic containment panels, structural hardware, a heat exchanger unit for the dual-circuit process
cooling, dust extraction filtration tools, vacuum units, and maintenance accessories are all sourced from
Switzerland.
Japan manufactures the primary robotic manipulator, specifically the FANUC M-710iC/50 robot assembly,
essential for precision gun handling. Germany contributes the heavy part-handling manipulator sub-system,
which includes the Takttisch indexing table, Robax-500 swing arms, specialized face plates, and integrated
pneumatic rotary walls. Germany also supplies protective dark windows for the booth and integrated
communication components for the cooling system’s heat exchanger.
Further European contributions include transparent glass for the booth from Belgium, and internal LED
lighting fixtures along with heavy chiller hose assemblies from Italy. Slovakia provides integrated specialized
flexible vacuum hoses. Finally, the United States is the source for the core application components,
manufacturing the HVOF hybrid spray guns, high-pressure orange powder feed hose assemblies, and
multi-use air, oxygen, and fuel connection lines. Basic hose clamps are also sourced from the United States.
The final assembly, mechanical and electrical integration, and system-level testing of the surface platform are
performed in Liechtenstein. This comprehensive process integrates a collection of modules and components
into a fully operational thermal spray coating system ready for its intended industrial application. The
assembly process involves six core steps and requires approximately 620 labor hours to complete.
The process starts with core system testing, which includes an electrical function test, leak test, software
installation, and calibration of the mass flow controller connecting to the feeder and multi-coat controller.
The subsequent step is mechanical integration, requiring personnel to prepare and mark the mounting field.
Following this, the coating module is positioned, the silencer is installed, and the extraction system is
connected. Components are then placed according to the established layout, and cable ducts are routed as per
the cable layout. The robot is installed within the coating module, and the K2 carousel is fitted, including the
bulkhead and pneumatics. The chiller is filled, water hoses are connected, gas hoses are laid, kerosene is
connected, and the spray gun is installed. Electrical integration follows, involving the preparation and
labeling of cables. All components are then wired before power is supplied to the unit, and various additional
tasks are completed.
The next phase is system start-up, which necessitates complete testing of the surface platform against a
predefined checklist. Upon completion of the start-up system testing, the surface platform undergoes a
factory acceptance test (FAT) conducted by an integration technician to verify product function and quality.
Once all preceding procedures are finalized, the mechanical, electrical, and installation components are
disassembled for packaging. Following complete disassembly, the materials are prepared for importation to
the United States.
When determining the country of origin, 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 thermal spray coating machines, it is our opinion that the assembly, testing and
calibration being performed in Liechtenstein substantially transforms the individual components sourced
from various countries. While some major subassemblies are created in Switzerland, it is not until the
complete unit is created in Liechtenstein that there is a functional robot capable of spraying. The total number
of man hours required to assemble the product in Liechtenstein, along with the complexity of the construction
and the skill required by the workers, involves more than a simple assembly process. Accordingly, in our
opinion, the surface platform undergoes a substantial transformation in Liechtenstein, where it receives a new
name, character, and use. Therefore, the country of origin will be Liechtenstein, which is where the
individual components are transformed into fully functional thermal spray coating machines.
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)
James P. Forkan
Director
National Commodity Specialist Division