Newly Released CBP HQ Rulings Jan. 5
The Customs Rulings Online Search System (CROSS) was updated on Jan. 5 with the following headquarters rulings (ruling revocations and modifications will be detailed elsewhere in a separate article as they are announced in the Customs Bulletin):
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H342833: Country of Origin of an Electronically Commutated Motor; Section 301 Trade Remedy
| Country of Origin: The country of origin of the Electronically Commutated Motor (ECM) for duty purposes will be Thailand. |
| Issue: What is the country of origin of the ECM motor for duty purposes? |
| Item: GMCC & Welling Appliance Component's electronically commutated motor manufactured in Thailand with parts from China, Japan and Thailand. The ECM motor is equipped with functions such as constant torque or constant speed. |
| Reason: CBP’s general position is that the country of origin of an electric motor will be determined by where the two most essential components of an electric motor, the rotor and the stator, are made. In turn, the country of origin of the stator and rotor will often be based upon the country where the cores of these components are made. CBP also has held that whether an assembly process is sufficiently complex to rise to the level of substantial transformation is determined upon consideration of all of the operations that occur within that country, including any subassembly processes that take place in that country. In the instant matter, CBP finds that the processing of the ECM motor in Thailand is similar to the processing that occurs in NY N320693 and NY N318006. The Chinese-origin stator subassembly and other non-Thai components are installed with the Thai-origin rotor subassembly and the Thai-origin structural bracket in Thailand. Additionally, the rotor and stator subassemblies of the DC electric motors in NY N320693 and NY N318006, and the rotor and stator subassemblies of the subject ECM motor originate in different countries. As in NY N320693 and NY N318006, the complex final assembly of the ECM motor occurs in the same country as where the rotor subassembly and another subassembly are manufactured, i.e., Thailand. Moreover, according to the bill of materials, the Thai processing and material costs outweigh the Chinese material costs. |
| Ruling Date: Dec. 19, 2025 |