The country of origin of a replacement water filter

N350082
June 25, 2025
OT:RR:NC:N1:105
CATEGORY: Origin Jamie Smith Access Business Group International LLC 7575 Fulton Street East Ada, MI 49355 RE: The country of origin of a replacement water filter Dear Mr. Smith: In your letter dated June 11, 2025, you requested a country of origin ruling on a replacement water filter. Descriptive literature was provided for our review. The item under consideration is described as the Calypso Water Filter, which is a replacement water filter used with the eSpring Water Treatment System. The filter uses a multi-stage process to purify water, combining a carbon-block filter with a UV lamp. The carbon filter reduces over 140 potential contaminants, including various health-effect contaminants, while the UV lamp eliminates 99.99% of waterborne bacteria and viruses. The filter cartridge is designed to be easily replaced without needing special tools, and a smart chip monitors system performance and alerts users when replacement is needed. The Calypso Water Filter is assembled in China using components manufactured in the United States, China, and Hungary. The filter is comprised of a United States origin carbon block, adhesive, and outer wrap. The Chinese origin components include the endcap cover, quartz retainer ring, lamp printed circuit board assembly (PCBA), crimped reflector, o-rings, bumper band, open end cap and radio frequency identification (RFID) assembly, quartz tube, and closed end cap. The UV lamp assembly is produced in Hungary. The carbon block is the most expensive portion of the filter and also performs the primary filtering function for the system. The carbon block removes contaminants from water through a process called “adsorption.” Adsorption is a process in which contaminants are attracted to the surface of the carbon granules and become trapped in the small pores of the filtration media. The assembly process in China starts with gluing and attaching the outer wrap to the exterior of the carbon block. This is followed by applying glue to both the open and bottom end caps and reflector to the filter assembly. Then, the reflector is inserted into the carbon filter assembly and the quartz sleeve is inserted into the reflector. Next, the lamp PCBA is pre-attached to the UV lamp before the UV lamp assembly is inserted into the quartz tube inside the filter assembly. The RFID is then inserted within the top cap and glued in place before testing and labeling. Finally, the o-ring is placed on the final assembly and closed with the top cap before packing and shipping to the United States.

When determining the country of origin, 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 origin of the Calypso Water Filter, the assembly process predominantly involves screwing, gluing and pressing various components into place. The combining of these parts in China does not create a new and different article of commerce with a name, character, and use distinct from the individual components. Therefore, to determine the country of origin of the replacement water filter, we rely on the origin of the carbon block, which provides the essential function of the filter. It is the carbon block from the United States which requires considerable technical experience and customized equipment to produce. It is also the most expensive portion of the filter, and it is the item performing the filtering of the water. Accordingly, the country of origin of the Calypso Water Filter will be the United States, which is where the carbon block is manufactured. 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 Jason Christie at [email protected].
Sincerely,
(for) Steven A. Mack Director National Commodity Specialist Division