N346867

N346867 April 16, 2025 OT:RR:NC:N1:103 CATEGORY: Origin Jasmine Masri Crowell & Moring 1001 Pennsylvania Avenue NW Washington, DC 20004 RE: The country of origin of an Industrial Robot Assembly and a Tightening Gun Assembly Dear Ms. Masri: In your letter dated March 17, 2025, you requested a country of origin ruling on behalf of your client, SK Automation America Inc. The first item under consideration is referred to as an Industrial Robot Assembly and identified as machine 120-02. The Industrial Robot Assembly is described as a robot arm, equipped with a customized gripper mechanism and a camera system, mounted atop a pedestal. The robot is used in a manufacturing station in an assembly line for producing high voltage distribution boxes (HVDB). In the manufacturing station, it is limited to performing a single function, described as picking up, moving, and placing certain components using its gripper mechanism. This request only concerns the Industrial Robot Assembly and not the entire manufacturing station. Based upon your submission, a finished Japanese robot arm is sent to China where additional components from Japan, China, and Vietnam are added. The additional components include a camera, a vacuum actuator, and a light source from Japan. A reflection sensor and beam sensor are also sourced from Vietnam. The main components sourced from China include the gripper mechanism (functioning as the end-of-arm tooling), a pedestal (where the robot arm is mounted), and various brackets, fixation blocks, and aluminum profiles. The assembly process begins with mounting the robot arm atop the pedestal and securing it using bolts. Next, workers begin assembling the gripper mechanism to the robot arm. The mechanism is composed of a series of aluminum profiles and brackets that form a platform-like base with both fixed and moving connection blocks. It is created by systematically attaching component pieces, securing them in place using bolts, and making necessary adjustments. This is followed by attaching a gripper cylinder, a vacuum actuator, a reflection sensor, and a beam sensor. A subassembly that incorporates a light source and camera system will also be attached to the base of the gripper mechanism. This unit is created using operational assembly steps described as installing the camera and its protective cover, installing the light source and its mounting base, and securing an IO module and its supporting brackets. When determining the country of origin for purposes of applying current trade remedies under Section 301, 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). CBP has held that whether an assembly process is sufficiently complex to rise to the level of a substantial transformation is determined upon consideration of all the operations that occur within that country. Here, the Japanese robot arm defines the final assembly and arrives in China as a complete product. It also accounts for the largest percentage by value among all components in the Industrial Robot Assembly. Based upon your description of the assembly process, the operational steps that follow in China are not sufficiently complex and do not transform the robot arm into an article with a new name, use, or character. Any additional assembly that occurs in China is solely described as installing the robot’s end-of-arm tooling and ancillary devices. Thus, based on the totality of the circumstances, the country of origin of the Industrial Robot Assembly, machine 120-02, as described above, will be Japan. The second item under consideration is described as a tightening gun assembly which allows a production line operator to manually rework the HVDB after inspection at the previous station. The tightening gun assembly comprises a total of 17 components, including, but not limited to, a tightening gun, an upright column, a mounting base, a mounting block, a positioning force arm, a rotating axis, a lifting ring, an encoder, and a fixing base. The tightening gun component delivers desired torque to efficiently tighten fasteners on a workpiece. It is located at the distal end of the positioning force arm and is the component which directly interacts with both operator and workpiece during operation. The positioning force arm is a telescopic extension that connects the tightening gun to the structural and rotational aspects of the upright column. The positioning force arm supports and stabilizes the tightening gun during operation and absorbs torque at the joint of the assembly. As a result, it provides ergonomic benefits to the operator. In addition, the positioning force arm allows for rotation of the tightening gun because it connects to swiveling components in the upright column. Based on the submitted documentation, the tightening gun from Sweden and the positioning force arm from Italy combine to account for most of the assembly’s material cost. Additionally, you state that the tightening gun from Sweden and the positioning force arm from Italy are exported to China as finished products for assembly with mainly Chinese origin components. Assembly in China begins with the installation of the column to the floor using four anchor bolts. Then, the seat is installed to the upright column using four screws and a bearing is installed into the seat. Next, a shaft is installed into the seat and a bearing is installed onto the upper portion of the shaft. At that point, a cover, coupling, and encoder assembly are installed, and the proximal end of the positioning force arm is connected using screws. At the terminal end of the positioning force arm, a connecting block, moving block, and shaft are assembled using screws and snap rings. After that, two screws are added to the locking block for connection to the tightening gun. Finally, the tightening gun spindle is prepared for installation and fixed to the locking block of the positioning force arm using screws. Your submission states that each assembly operation combines components by common fasteners (bolts, screws, etc.) and takes 10 minutes or less to complete. In total, the assembly operations in China span approximately 50 minutes from start to finish. In this case, the tightening gun from Sweden imparts the essential character of the tightening gun assembly. The tightening gun is the indispensable component which principally and directly delivers torque to tighten fasteners on an HVDB. Furthermore, it is the most expensive component in the tightening gun assembly. Although the positioning force arm from Italy is also expensive and functionally significant, it provides support, stability, and limited movement for the tightening gun. As a result, it is subservient to the tightening gun?s function in the overall assembly. Lastly, the components from China are less significant, less complex, and less expensive compared to the tightening gun. These components mainly provide structural support in the assembly. In summary, the tightening gun from Sweden arrived in China with a predetermined end-use. Moreover, the simple assembly operations in China with less-significant components do not substantially transform the tightening gun into a new article. After assembly operations in China, no article emerges with a new name, character, or use. Since the tightening gun from Sweden imparts the essential character of the tightening gun assembly and it is not substantially transformed in China, the country of origin of the tigh

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). CBP has held that whether an assembly process is sufficiently complex to rise to the level of a substantial transformation is determined upon consideration of all the operations that occur within that country. Here, the Japanese robot arm defines the final assembly and arrives in China as a complete product. It also accounts for the largest percentage by value among all components in the Industrial Robot Assembly. Based upon your description of the assembly process, the operational steps that follow in China are not sufficiently complex and do not transform the robot arm into an article with a new name, use, or character. Any additional assembly that occurs in China is solely described as installing the robot’s end-of-arm tooling and ancillary devices. Thus, based on the totality of the circumstances, the country of origin of the Industrial Robot Assembly, machine 120-02, as described above, will be Japan. The second item under consideration is described as a tightening gun assembly which allows a production line operator to manually rework the HVDB after inspection at the previous station. The tightening gun assembly comprises a total of 17 components, including, but not limited to, a tightening gun, an upright column, a mounting base, a mounting block, a positioning force arm, a rotating axis, a lifting ring, an encoder, and a fixing base. The tightening gun component delivers desired torque to efficiently tighten fasteners o