H337371

H337371 April 24, 2025 OT:RR:CTF:VS H337371 RRB CATEGORY: Origin Jeffrey G. Richardson Miller, Canfield, Paddock and Stone, P.L.C. 840 W. Long Lake Road, Suite 150 Troy, MI 48098 RE: Country of Origin of an Automotive Fuel Pump; Section 301 Trade Remedy Dear Mr. Richardson: This is in response to your request, dated February 12, 2024, filed on behalf of your client, Joinhands Injection System (Thailand) Co. Ltd.(“Joinhands-Thailand”), regarding the country of origin of an Automotive Fuel Pump. In response to our requests for additional information, you submitted supplemental submissions, dated October 18, 2024; November 26, 2024; February 18, 2025; February 21, 2025; and February 25, 2025. Our office also held a meeting with you on February 28, 2025. You have requested that certain information submitted in connection with this ruling request be treated as confidential. On October 8, 2024, you provided an amended version of your submission, narrowing the parameters of your confidentiality request. Inasmuch as the amended scope of your confidentiality request conforms to the requirements of 19 C.F.R. § 177.2(b)(7), the request for confidentiality is approved. FACTS: Joinhands Auto Spare Parts Co., Ltd (“Joinhands-China”) manufactures and distributes fuel injectors, fuel pumps, and other automotive parts. It is headquartered in Jiaxing, Zheijiang Province of China. Joinhands-China is the corporate parent of Joinhands-Thailand, which operates a manufacturing facility in the Rayong Province of Thailand, and is capable of manufacturing fuel pumps and fuel pump modules. The merchandise at issue is an Automotive Fuel Pump that extracts fuel from the tank and supplies fuel to the engine at a constant pressure and output power. The Automotive Fuel Pump services piston-type internal combustion engines that convert energy produced by the combustion of fuel into mechanical energy. The Automotive Fuel Pumps are ultimately used in passenger vehicles, medium and heavy-duty trucks, and commercial vehicles, as well as all-terrain vehicles and utility task vehicles. Joinhands-Thailand states that the key assembled components of the subject Automotive Fuel Pump consist of the following: pump core/motor subassembly, inner support, and reservoir. The purpose of the pump core within the pump core/motor subassembly is to pump out fuel from the fuel tank using the motor. Joinhands-Thailand further explains that the pump core/motor subassembly serves as the essential component of the Automotive Fuel Pump and contains the electric motor, including the armature, which turns the turbine blade at high speed to create and maintain the pressure needed for the Automotive Fuel Pump to correctly function. The reservoir stores fuel, ensuring long term immersion of the pump within the fuel, while the inner support is fixed to the Automotive Fuel Pump to connect it to the flange. The Pump Core/Motor Subassembly Joinhands-Thailand explains that the electric motor contained within the pump core/motor subassembly represents the essence and primary function of the Automotive Fuel Pump. It also explains that the armature is the key component of the electric motor within the Automotive Fuel Pump. The following manufacturing steps occur in Thailand to produce the armature: press-fitting the shaft through the center of the lamination stack; assembling the insulation coat; pressing the commutator; winding; welding; comprehensive testing of semi-finished products; armature injection; finishing the commutator; balancing measurements; moving and inspecting the burr; and comprehensive testing of the finished products. In total, 7 discrete parts are sourced from various countries, including 3 parts from Thailand, 3 parts from China, and 1 part from Japan, which are assembled together in Thailand through 11 separate steps to produce the armature component. The following manufacturing steps also occur in Thailand to produce the rest of the pump core/motor subassembly: manually inserting the valve stem, checking the valve plug with a hand tool, and press-fitting into place; leakage test; installing an oil bearing by manually inserting the ring and press-fitting into place; manually inserting the relief valve spring, rubber ball, and relief valve plug with a hand tool and press-fitting into place; riveting the brush and inductance components; manually inserting the brush and inductor components into the lower die with a copper clamp that is press-fit to tightly connect the components together; soldering; installing a shell cover into the pump shell through pneumatic press-fitting; manually installing a magnet steel spring and retaining clip that is then crimped into place; magnetizing and installing the armature; installing 2 the impeller components through manual insertion into the pump casing; installing the back cover through press-fitting; measuring the current seal; run-in testing; comprehensive checks; removing residual oil; and packing into the warehouse. In total, 17 discrete parts are sourced from various countries, including 6 parts from Thailand, 10 parts from China, and 1 part from Japan, which are assembled together in Thailand through 17 separate steps to produce the pump core/motor subassembly (not including the 11 manufacturing parts and steps involved in producing the armature). According to the bill of materials of the finished Automotive Fuel Pump that Joinhands-Thailand submitted with its ruling request, the pump core/motor subassembly manufactured in Thailand constitutes the largest percentage of the cost breakdown of the Automotive Fuel Pump, making up [ ]% of the Automotive Fuel Pump based on cost percentage.1 Manufacturing of Other Constituent Parts: Reservoir and Inner Support Other constituent parts that Joinhands-Thailand identifies as key components of the Automotive Fuel Pump include the reservoir and inner support. The reservoir subassembly is manufactured in Thailand and stores fuel, ensuring long term immersion of the pump within the fuel. After the pump core/motor subassembly, the reservoir comprises the second largest percentage of the cost breakdown of the Automotive Fuel Pump, making up [ ]% of the finished product, due to the large size of its plastic injection molded container. Along with the reservoir subassembly, the inner support is also manufactured in Thailand through a plastic injection molding process and comprises the third largest percentage of the cost breakdown of the Automotive Fuel Pump at [ ]%. Other constituent parts manufactured at Joinhands-Thailand’s facility in Thailand include the flange (upper cover), electrical connector, and fuel level sensor. The flange (upper cover) and electrical connector are manufactured through plastic injection molding, while the fuel level sensor is manufactured by soldering resistor wire ends onto a plastic holder, with a wire harness tie-strapped together and a fuel level float rod plastic plug that is press-fit into place. Final Assembly of the Automotive Fuel Pump Joinhands-Thailand explains that the pump core/motor subassembly and constituent parts, including the reservoir and inner support, are assembled into the final Automotive Fuel pump in Thailand. The final assembly of the Automotive Fuel Pump in Thailand consists of 17 unique parts plus the completed pump core/motor subassembly (comprising 23 separate parts that have already been assembled into the pump 1 Labor and packing costs in Thailand for the inished Automoive Fuel Pump are accounted for separately and consitute [ ]% of the total cost percentage of the Automoive Fuel Pump. 3 core/motor subassembly in Thailand). The processing steps in Thailand for final assembly of the Automotive Fuel Pump include: pressing the connector on the top cover; assembling the sensor on the top cover; testing the leakage of the top cover; pressing the rollover valve on the top cover; testing the leakage of the rollover valve; pressing the holder on the top cover; pressing th

When determining the country of origin for purposes of applying trade remedies under Section 301, the substantial transformation analysis is applicable. 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 (CCPA 1982). In deciding whether the combining of parts or materials constitutes a substantial transformation, the determinative issue is the extent of operations performed and whether the parts lose their identity and become an integral part of the new article. See Belcrest Linens v. United States, 6 CIT 204, 573 F. Supp. 1149 (1983), aff’d, 741 F.2d 1368 (Fed. Cir. 1984). Assembly operations that are minimal or simple, as opposed to complex or meaningful, will generally not result in a substantial transformation. Factors which may be relevant in this evaluation include the nature of the operation (including the number of components assembled); the number of different operations involved; and whether a significant period of time, skill, detail, and quality control are necessary for the assembly operation. See C.S.D. 80-111, C.S.D. 8525, C.S.D. 89-110, C.S.D. 89-118, C.S.D. 90-51, and C.S.D. 90-97. If the 2 Labor and packing costs in Thailand for the inished Automoive Fuel Pump are accounted for separately and consitute [ ]% of the total cost percentage of the Automoive Fuel Pump. 4 

manufacturing or combining process is a minor one which leaves the identity of the article intact, a substantial transformation has not occurred. See Uniroyal, Inc. v. United States, 3 CIT 220, 542 F. Supp. 1026 (1982), aff’d, 702 F.2d 1022 (Fed. Cir. 1983). The Court of International Trade more recently interpreted the meaning of “substantial transformation” in Energizer Battery, Inc. v. United States, 190 F. Supp. 3d 1308 (CIT 2016). Energizer Battery involved