OT:RR:NC:N1:102
Dinghe Zheng
Sontian Motor (Thailand) Co. Ltd.
Khlong Udom Chonlachon Sub-District
Mueang Chachoengsao District
Thailand
RE: The country of origin of a fan assembly
Dear Mr. Zheng:
In your letter dated June 30, 2026, you requested a country of origin ruling.
The item at issue is a fan assembly (product number TSF8010002). The assembly primarily consists of a
rectangular shaped fan shroud and a fan blade powered by a motor. Once installed onto the radiator of a
motor vehicle, the assembly dissipates heat from a water tank and the radiator.
Regarding the country of origin, the fan assembly is manufactured in Thailand using components sourced
exclusively from Thailand. The assembly process entails joining the fan blade and motor using a pneumatic
tool and a locknut. The completed motor-blade assembly is then fastened to the shroud. Inspections are
conducted at each stage of the assembly process.
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).
Based on the information provided, all components of the fan assembly are manufactured and assembled in
Thailand. Although the final assembly process is simple and does not result in a change in name, character, or
use, the components, including the motor, which constitutes the essence of the assembly, are of Thai origin.
Therefore, based on the totality of the circumstances, the country of origin for the fan assembly will be
Thailand.
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 Sandra Martinez at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division