N358288

N358288 February 5, 2026 OT:RR:NC:N1:105 CATEGORY: Origin Ryan Supek TE Connectivity Corporation 2800 Fulling Mill Road Middletown, PA 17057 RE: The country of origin of pressure sensors Dear Mr. Supek: In your letter dated January 28, 2026, you requested a country of origin ruling on pressure sensors. Descriptive literature was provided for our review. This ruling addresses four distinct models of pressure sensors, identified by part numbers 20005327-42, 11026687-00, 4525-DS5A001GP, and 20008088-03. The 20005327-42 Pressure Sensor is a piezoresistive strain gauge sensor encased in a stainless-steel housing. This product is designed for industrial and commercial Original Equipment Manufacturers (OEMs) engaged in small to high-volume semiconductor manufacturing equipment. The stainless-steel packaging renders the sensor compatible with both gas and liquid media, enabling it to measure the volume of these substances within semiconductor manufacturing equipment chambers. The sensing package functions by transferring pressure from a stainless-steel diaphragm to the internal sensing element. The 11026687-00 Pressure Transducer is also a piezoresistive strain gauge pressure sensor, similarly packaged in a stainless-steel housing. It is intended for industrial and commercial manufacturers across a range of small to high-volume applications. The stainless-steel encapsulation ensures its compatibility with gas and liquid media. The 4525-DS5A001GP Pressure Transducer is engineered for pressure measurement in OEM applications. It is manufactured utilizing a proprietary UltraStable process, which guarantees long-term stability and reliability. This transducer incorporates advanced complementary metal-oxide-semiconductor (CMOS) sensor conditioning circuitry to deliver high performance at a competitive cost. Employing micro-electro-mechanical systems (MEMS)-based piezoresistive sensing technology, it converts applied pressure into an electrical signal. The sensing element is mounted on a ceramic substrate and protected by a ceramic cover. The signal is subsequently processed and calibrated by an Application-Specific Integrated Circuit (ASIC). This device is available in multiple configurations, including side port, top port, and manifold mount, to accommodate diverse installation requirements. Finally, the 20008088-03 Pressure Sensor is specifically designed for use in medical instruments, factory automation systems, and leakage detection applications. It employs MEMS-based piezoresistive sensing technology to convert applied pressure into an electrical signal. The assembly comprises a MEMS chip (sensing die) mounted on a header and secured with adhesive. Electrical connection is established via integrated pins, which transmit the converted voltage signal. Each pressure sensor has its own unique (but similar) manufacturing process as outlined below. The manufacturing process for the 20005327-42 Pressure Sensor starts with the sensing gauge, fabricated in wafer form, being produced at a wafer manufacturing facility in Germany. The wafer undergoes etching, processing, and qualification to ensure adherence to all required performance specifications. At this stage, the die within the wafer is capable of sensing pressure and providing an electrical output when probed. Upon completion, the wafer is transported to China for subsequent assembly. In China, the wafer is diced into individual gauges in preparation for assembly. The housing (port) is subjected to surface sanding and plasma cleaning prior to the bonding of the gauges with a glass paste adhesive. This assembly is then fired and glazed, permanently securing the gauges to the port. Electrical connections are established via wire bonding between the gauges and the printed circuit board assembly (PCBA), followed by a visual inspection to verify proper placement and bonding integrity. Subsequently, the middle sensor housing (HEX), bracket, and functional PCBA are integrated into the sensor assembly through soldering and welding processes. The part number and serial number are then laser-marked onto the HEX. The subassembly undergoes calibration and functional testing to confirm performance specifications. Following calibration, a connection module is produced by soldering a connector to a flexible printed circuit board (FPCB), which is then housed and secured with epoxy. This module is integrated with the subassembly by soldering the FPCB between the two modules, and the entire product is sealed using laser welding. Finally, the completed sensor module undergoes insulation and functional testing at room temperature before being packaged for shipment. The manufacturing process for the 11026687-00 Pressure Transducer begins with the sensing die, produced in wafer form, which is manufactured at a wafer fabrication facility in the United States. It undergoes etching, processing, and qualification to ensure compliance with all required performance specifications. At this stage, the die within the wafer is capable of sensing pressure and providing an electrical output when probed. Upon completion, the wafer is shipped to China for the remaining manufacturing steps. In China, the wafer is diced into individual dies. Each die is assembled into a capsule, followed by a visual inspection. The capsule assembly is then welded to the fitting. After a subsequent visual check, a flexible printed circuit board (FPCB) is wire bonded to the top of the capsule to enable electrical signal connection. A further inspection verifies the integrity of this connection. Next, a sensor housing (HEX), bracket, and functional PCBA are integrated into the sensor assembly through soldering and welding. The part number and serial number are then laser-marked onto the HEX. The subassembly undergoes calibration and functional testing to confirm performance. Following calibration, a connection module is produced by soldering a connector to an FPCB, which is then housed and secured with epoxy. This module is integrated with the subassembly by soldering the FPCB between the two modules, and the entire product is sealed using laser welding. Finally, the completed sensor undergoes insulation and functional testing at room temperature before being packaged for shipment. The manufacturing process for the 4525-DS5A001GP Pressure Transducer starts with the sensing die, produced in wafer form, being fabricated at a wafer manufacturing facility in the United Kingdom. The wafers are etched, processed, and qualified to ensure they meet the desired performance characteristics. At this stage, the die within the wafer can sense pressure and provide an electrical output when probed. The wafers are then shipped to China, where the remaining manufacturing process occurs. Upon arrival in China, the wafers are diced into individual dies in preparation for assembly. The die is mounted onto the substrate, followed by wire bonding to establish electrical connections between the die, the ASIC, and the substrate pads. Subsequently, the top lid is affixed to the substrate using epoxy, providing protection for the die and wire bonds. A lower lid is then attached with epoxy to secure internal components, relieve mechanical stress, and ensure environmental sealing. The assembly then undergoes a laser marking process, which is a calibration step involving the application of laser energy to fine-tune the electrical characteristics of the sensor die or related components to meet exact performance parameters. Following laser marking, the assembly undergoes adhesive curing and cleaning. The completed sensor undergoes functional testing before being packaged for shipment. Finally, the manufacturing process for the 20008088-03 Pressure Sensor starts with the sensing die, produced in wafer form, in a wafer fabrication facility in the United States. The wafers are etched, processed, and qualified to ensure they meet the desired performance characteristics. At this stage, the die within 

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 “substantial transformation” principle, which dictates that the country of origin is where an article emerges from a manufacturing process with a new name, character, or use distinct from its original form, the origin of the four pressure sensor models is determined by the country where the essential pressure-sensing component is produced. For the 20005327-42 Pressure Sensor, the sensing gauge (strain gauge die) manufactured in Germany imparts the character and functionality of the finished product, as it can independently sense pressure and emit an electrical output upon leaving Germany. Ancillary components, such as the PCBA and FPCB, serve only to amplify signals, provide standard output, or facilitate connections, without possessing pressure-sensing capabilities or installed software. The subsequent assembly operations in China, involving encapsulation, soldering, gluing, wire bonding, welding, and calibration, are deemed simple assembly and do not result in a new name, character, or use for the article. Therefore, the country of origin for the 20005327-42 Pressure Sensor is Germany. Similarly, for the 11026687-00 Pressure Transducer, the sensing die, produced in the United States, imparts the character and function of the finished project, capable of independent pressure sensing and electrical output. The PCBA and FPCB are ancillary, providing signal amplification, electromagnetic compatibility protection