N351455

N351455 August 7, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Long Chen Thai Jiuzhou Electron Co. LTD 88/152 Moo 15 Bangsaotong Sub-District Bangsaotong 10540 Thailand RE: The country of origin of a spark module for a gas range Dear Mr. Chen: In your letter dated July 17, 2025, you requested a country of origin ruling on a spark module for a gas range. The merchandise under consideration is described as a spark module for a gas range stove and is identified by part numbers 311D7051P001, 311D7051P002, 311D7051P003, and 311D7051P004. It is noted that the different variations are virtually identical and only differ by the specific appliance with which they will be used. The spark module is attached to a gas range oven and is responsible for generating a high-voltage spark to ignite the gas at the burners. Two configurations were provided for the manufacturing of the spark module. The first configuration has a high voltage (HV) coil, Printed Circuit Board Assembly (PCBA), cover, and epoxy potting all manufactured in China, then shipped to Thailand. In Thailand, the PCBA and HV coil are assembled together. The primary coil lead and terminal are soldered to the PCBA, then are tested. Once testing is complete, epoxy potting is added to shield the device from the environmental factors and distress. The device is tested again for functionality, and once confirmed, the cover is added, the device is tested, date coded, and packaged in Thailand for export to the United States. The second configuration has an HV coil, cover, and epoxy potting originating in China. The PCBA is manufactured in Thailand. The Chinese components are shipped to Thailand, where the PCBA and HV coil are assembled together. The primary coil lead and terminal are soldered to the PCBA, then are tested. Once testing is complete, epoxy potting is added to shield the device from the environmental factors and distress. The device is tested again for functionality, and once confirmed, the cover is added, the device is tested, date coded, and packaged in Thailand for export to the United States. When determining the country of origin for purposes of applying current trade remedies under Section 301 and 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). Regarding the subject of the spark module, it is the opinion of this office that for Configuration 1, the Chinese PCBA which sends the electrical signal to increase the power supply to charge the capacitor and discharge to release the pulse signal to create a spark which ignites the gas, imparts the character of the finished device. The assembly process in Thailand is simple in nature and does not substantially transform the PCBA or other Chinese components into a new and different article of commerce. Based on the facts presented for configuration 1, the Country of Origin for the spark module for part numbers 311D7051P001, 311D7051P002, 311D7051P003, and 311D7051P004 will be China. Regarding Configuration 2, the PCBA manufactured in Thailand, which sends the electrical signal to increase the power supply to charge the capacitor and discharge to create a spark which ignites the gas, imparts the character of the finished device. The assembly process in Thailand is simple in nature. Based on the facts presented for Configuration 2, the Country of Origin for the spark module for part numbers 311D7051P001, 311D7051P002, 311D7051P003, and 311D7051P004 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 Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, James Forkan Acting Director National Commodity Specialist Division

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). Regarding the subject of the spark module, it is the opinion of this office that for Configuration 1, the Chinese PCBA which sends the electrical signal to increase the power supply to charge the capacitor and discharge to release the pulse signal to create a spark which ignites the gas, imparts the character of the finished device. The assembly process in Thailand is simple in nature and does not substantially transform the PCBA or other Chinese components into a new and different article of commerce. Based on the facts presented for configuration 1, the Country of Origin for the spark module for part numbers 311D7051P001, 311D7051P002, 311D7051P003, and 311D7051P004 will be China. Regarding Configuration 2, the PCBA manufactured in Thailand, which sends the electrical signal to increase the power supply to charge the capacitor and discharge to create a spark which ignites the gas, imparts the character of the finished device. The assembly process in Thailand is simple in nature. Based on the facts presented for Configuration 2, the Country of Origin for the spark module for part numbers 311D7051P001, 311D7051P002, 311D7051P003, and 311D7051P004 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 th