N344002

N344002 December 6, 2024 OT:RR:NC:N1:102 CATEGORY: Origin; USMCA; Marking Lynne Wendt Wendt and Temples, LLC Westpark Pointe, Suite 200 401 Westpark Court Peachtree City, GA 30269 RE: The country of origin of hermetic compressors Dear Ms. Wendt: In your letter dated November 13, 2024, you requested a country of origin ruling on hermetic compressors on behalf of Jiaxipera Mexico S. de R.L. de C.V. Technical information was submitted with your request. The items for consideration are described as hermetic compressors for refrigeration appliances, models TB1114HY, TH1114HY, and TU1112HY. During operation, the compressors function to move refrigerant through the cooling system of an attached appliance. The primary components of hermetic compressors are the stator, rotor, housing, crankcase, crankshaft, piston, piston pin, connecting rod, internal discharge tube, oil pump, valve components, nameplate, and cover. Additional components incorporated during assembly include, but are not limited to, screws, washers, wire, gaskets, and ball bearings. The shell of the compressor is constructed from steel sheet. The top portion is welded to the bottom portion, creating a hermetically sealed connection which prevents refrigerant from leaking to the outside. The stator is a lamination stack of steel sheet together with two windings of copper wires. The rotor is a lamination stack that is cast in aluminum. The crankshaft is connected to the rotor and transmits the rotation of the motor into reciprocating strokes of the piston. As a result, the cylinder moves up and down and allows refrigerant to be drawn in, compressed, and discharged. Refrigerant is pulled into the compressor through a suction connector, and it is routed out by a discharge connector. Valves assist with opening and closing the valve plates during the suction and discharge actions. In addition, the compressors are fitted with internal springs to reduce vibration and a muffler to reduce noise. Assembly of the hermetic compressors will occur in Mexico of mostly Chinese origin components, with the exception of aluminum ingot purchased in Mexico but sourced from India, assembly oil sourced from the U.S., and packing materials sourced from Mexico. Of note, the stators and rotors will be manufactured in Mexico from Chinese-origin materials. The mechanical unit consisting of the motor, cylinder, and valves will be assembled into the bottom housing in Mexico. In your submission, you state the manufacturing process requires several trained employees and various machinery to complete 86 separate operations that cover the stator, rotor, lower housing, and compressor. Stator production begins with the loading of steel lamination sheet into the feeder of a lamination stacker machine to produce a lamination stack to specifications. The formed lamination stack is placed on a transfer rack where slot insulation of polyester film is inserted into 24 slots on the lamination stack. A main coil winding machine places the main phase winding of enameled wire and inserts the main winding into the lamination slots. In the first forming process, a coil forming machine forms the main winding ends to a specified sharpness. The winding is then manually checked by an employee for indentations and wedge integrity and a lead wire is placed into the correct location. Next, an employee winds the auxiliary winding into the lamination stack using an auxiliary winding machine. A laser marking machine marks the lamination stack with the stator model number, production date, and serial number. During the second forming process, a coil forming machine forms the auxiliary winding. After that, an employee crimps the main, auxiliary and common ends of the stator together with the wire harness using a crimping machine. An employee assembles the heat shrink tubes and manually covers the crimped terminal ends. Four employees complete the lead finishing by manually sorting outgoing lines and inserting them into the windings. In the third forming process, a coil forming machine starts to form the winding ends of the stator. Following that, two lacing machines lace the winding ends. In final forming, the stator is put into reshaping tooling of a coil forming machine to reshape the winding end size. Using an inner hole rolling machine, burrs from the stator hole are rolled and removed. After final shaping, four employees perform visual inspection of the stator for defects. Finally, an employee performs several tests for quality assurance and places the qualified stator in a storage box. Centrifugal casting rotor production begins with an employee attaching a cap to a rotor lamination stack and placing it on a conveyor belt of the production line. The following step is the centrifugal casting process in which the rotor lamination stack is heated to 320 degrees Centigrade. Using an aluminum melting furnace and a centrifugal casting machine, liquid aluminum is poured into the lamination stack rotating at high speed. Pouring the aluminum in this manner allows it to fill the lamination slots and solidify under the action of centrifugal force. Utilizing a combined processing machine and a roller, the centrifugally cast rotor is air cooled and undergoes processing such as removal of the casting port, marking, and inner hole rolling. In the last step of rotor production, an employee performs a waveform test utilizing a waveform detector and places the qualified rotor in a storage box. The lower housing welding line begins with an employee taking a lower compressor housing from its storage location and placing it on the production line. Then, an employee welds four ejector pins and two foot plates to the lower housing. Employees weld the process tube, suction tube, and discharge tube to the housing in succession and position each to the upper electrode. The hermetic terminal and terminal fence are then welded to the lower housing. Following that, the inner discharge tube is bent as required and the lower housing is laser marked using a laser marking machine. In the final step, an employee installs an insulation sheet onto the hermetic terminal as specified. The compressor production line is comprised of three different lines connected to each other with a transfer mechanism. First, an employee loads a crankcase onto a fixed board in the assembly line and brushes and cleans the piston hole. After measuring the piston hole diameter, an employee selects an appropriately sized piston, measures the fit clearance, and inserts it into the crankcase using an air gauge. Washers and ball bearings are attached to the crankcase using a bearing assembly machine. After measuring the crankshaft hole, an employee selects the correct crankshaft, applies assembly oil, and inserts it into the crankcase. Next, an employee selects the correct connecting rod and piston pin and assembles them using an air gauge. An elastic pin is then placed inside the piston and piston pin. A machine presses the elastic pin into final position and adds an appropriate amount of assembly oil to the connecting rod and piston surface. Subsequently, four employees pre-assemble the valve group by manually connecting the cylinder head, gasket, valve plate, security clip, suction motor, and suction valve with four screws. Once measurements are obtained, a gasket selection machine selects the corresponding valve plate gasket and uses a manipulator to place it on the crank case. The selected valve plate gasket and pre-assembled valve group is manually put together by an employee and then pre-tightened using a cylinder head pre-tightening machine. Four screws of the cylinder head are then finely tightened using four torque machines. At this point, a robot turns the mechanical kit upside down and places it on the tooling plate of the next assembly line. Insulation sheets are placed on the crankcase using an insulation sheet placement machine. An employee takes a stator from the storage location and assemb

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).In headquarters ruling H326072, dated January 25, 2024, CBP considered the country of origin of a reciprocating hermetic compressor sold to home appliance manufacturers for installation in refrigerators and freezers, which is similarly configured to the subject compressors. In part, ruling H326072 held that the country of origin of the hermetic compressors is controlled by where the stator and rotor, the two most essential components of an electric motor, are made. Furthermore, the extent of processing that occurs after the stator and rotor cores are created must also be taken into account. See also NY N309707, dated March 11, 2020; NY N308827, dated January 21, 2020; and NY 316151, dated December 18, 2020.In scenario two of H326072, a rotor lamination stack from China underwent extensive additional processing in Thailand such as injection with molten aluminum, creation of the rotor assembly, and assembly with a stator and other parts to create the motor. In combination with the other extensive assembly operations that occurred in Thailand to create the rest of the compressor, the country of origin was determined to be Thailand. In scenario three, the stator laminates from China were combined to create the stator core, bound, then wound with enameled wire in Thailand. The wire was then shaped, insulated, reshaped, and tied. Additionally, the inner surface of the stator was ground, tested, and assembled with the rest of th