OT:RR:NC:N2:206
Xiaozhen Qiao
Joinhands Injection System (Thailand) Co., Ltd.
890 / 25 Moo 3 Khao Khan Song Subdistrict, Si Racha District, Chonburi Province Si Racha District 20110 Thailand
RE: The country of origin of a fuel injector assembly
Dear Ms. Qiao:
In your letter dated February 25, 2025, you requested a country of origin ruling on a fuel injector assembly.
The article under consideration is the Fuel Injector Assembly, part number INJ-FRA001, which is a component of the automotive fuel supply system. It is a solenoid valve that connects to the fuel rail and the intake manifold, and controls the fuel injection volume and injection timing. When the vehicle is running, the fuel injector sprays an appropriate amount of fuel into the intake manifold according to the operating state and requirements of the engine. The fuel mixes with air to form a combustible mixture, providing necessary fuel support for the engine's combustion process ensuring that the engine can operate in a stable and efficient manner. The fuel injector can accurately adjust the activation time and injection volume according to the pulse signal issued by the electronic control unit (ECU), enabling the engine to maintain good performance under different operating conditions. This type of fuel injector is suitable for operating conditions with fuel pressure below 800 kPa.
The fuel injector assembly consists of a fuel rail and eight fuel injectors connected to a fuel pass tube. You state that the fuel injector armature and power group are made in Thailand, while the rest of the components are imported from China and Japan for further assembly. The body of the fuel rail, as well as the fuel pass tube and inlet press ring, are made in Thailand. The rest of the components of the fuel rail are made in China and imported to Thailand for further assembly. In Thailand, all components are combined together to create a complete fuel injector assembly. You provided videos of how each Thai component is made and the final assembly of all components into the fuel injector assembly.
The following are the steps undertaken in Thailand:
The armature is made by machining, offloading, and de-oiling the rod material. The power-group manufacturing process is made by bobbin pins assembly, wire winding, resistance welding, electromatic ring welding, press adjusting tubes, inlet tube magnetic ring laser welding, electromagnetic ring cover laser welding, and injection molding. The fuel injector is manufactured by assembling the Chinese valve seat and spring, and the Thai armature and power-group assembly.
The body of the fuel rail is made by heating, molding, and offloading plastic material. The regulator is made by assembling the ball and pocket, pocket and housing, diaphragm and retainer, then cover and housing pressing, flow pressure adjusting, purging, testing, and laser marking. Finally, all components are assembled together and tested to create a fuel injector assembly.
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 information provided, the processes in Thailand substantially transform the individual components from China and Japan into the fuel injector assembly. These processes are sufficiently complex and meaningful as to result in a substantial transformation, such that the non-originating components lose their individual identities and become an integral part of a new article, possessing a new name, character and use. Therefore, the country of origin for the Fuel Injector Assembly, part number is INJ-FRA001, 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 Liana Alvarez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division