OT:RR:NC:N2:220
Ms. Shurong Zeng
Sitronic Automotive Technology Co., Ltd
168/14 Moo.3 Map Kha, Nikhom Phatthana
Rayong 21180
Thailand
RE: The country of origin of an automotive headlight switch assembly
Dear Ms. Zeng:
In your letter dated September 27, 2026, you requested a country of origin ruling.
The item under consideration in this request is an automotive headlight switch assembly, model number
KD-2002, which is a multi-function switch assembly used to control a vehicle’s headlights and instrument
illumination intensity level. The automotive headlight switch assembly is installed in close proximity to the
driver’s seating position in a vehicle for the purpose of adjusting the vehicle’s instrument panel illumination
intensity level and selecting the exterior lighting such as headlights OFF, headlights ON, headlights AUTO
ON/OFF, and parking lamps only ON.
In Thailand, electronic components such as resistors, diodes, and LEDs are assembled onto a bare printed
circuit board via surface mount technology (SMT). In Thailand, with components sourced from China and
Thailand, the PCBA is further assembled into a plastic housing with other switch components including
electrical contacts, springs, and mechanical components such as a Rotary Knob and Rotary Wiper Contacts to
make a complete automotive headlight switch assembly. The finished assembly is inspected, tested, and
packaged for export to the United States.
When determining the country of origin for purposes of applying current trade remedies under Section
301and 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).
Additionally, 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.
Regarding the country of origin of the automotive headlight switch assembly, in our view the assembly of the
PCBA in Thailand by soldering the individual components onto the bare board results in a substantial
transformation of the individual components to produce a PCBA of Thai origin. Furthermore, it is the opinion
of this office that the PCBA establishes the function of the automotive headlight switch assembly because it
is the article within the assembly that opens and closes the electrical circuit and provides the electrical control
function. As such, we find that the individual components that make up the automotive headlight switch
assembly are transformed in Thailand into a new article of commerce with a different name, character, and
use. Thus, the automotive headlight switch assembly, model number KD-2002 is considered a product of
Thailand for origin and marking purposes at time of importation into 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 Gary Chaffee at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division