The country of origin of a green cartridge filter

N350920
July 22, 2025
OT:RR:NC:N1:105
CATEGORY: Origin Anchalika Prachakool QAP Filter (Thailand) Co., Ltd. 350/40 Moo 6, Nongbua subdistrict, Bankhai district Rayong 21120 Thailand RE: The country of origin of a green cartridge filter Dear Ms. Prachakool: In your letter dated July 3, 2025, you requested a country of origin ruling on a green cartridge filter. Descriptive literature was provided for our review. The item under consideration is described as a green cartridge, which is an engine filter designed to filter metal shavings and sludge, keep the engine oil clean, protect the engine, and remove oxidized carbon deposits and gel-like sediment. To install the filter, the user would first remove the old filter using a torque wrench. Then they would clean the housing, and replace and lubricate the O-ring before installing the new filter. The user would position the new filter into the cap ensuring a click is heard before putting it into the shell and replacing the cover. The green cartridges are assembled in Thailand using components from Thailand and China. The Thai components include the filter element assembly, filter paper assembly, origami (pleating or folding of the filter paper to increase its surface area for more efficient filtration), and some of the packaging including corner protectors, a cover plate, a pallet, and an outer box. The Chinese components include the upper-end cover, lower-end cover, filter paper, hot melt adhesive, central tube, O-ring, and some of the packing that includes the instructions, a paper box, and labels. The assembly process occurs in Thailand and includes fourteen individual steps. The process starts with the origami, which is made on a reciprocating origami machine. Next, the paper is slit and broken so that it can be rolled onto the central tube. This is followed by adding clamping strips using an automatic clamping machine. Then, the lower cover is filled with glue before being fitted with the paper core. Once complete, the product is sent to the oven for curing. After curing, the process shifts to laser cutting of the yellow velvet cotton and the ultrasonic welding of the yellow velvet cotton. Then it goes to a 4/6 hot plate welding machine before the filter element is wound on a winding machine. Next, comes the O-ring assembly, code spraying, and laser marking and, finally, packaging for shipment 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 green cartridge, it is our opinion that the manufacturing and assembly process performed in Thailand is considered complex. Numerous steps are needed to transform the individual components from China into a finished green cartridge in Thailand. The individual components each have a change in name, character, and use. Therefore, in our opinion, the country of origin of the green cartridge is Thailand, which is where the assembly process occurs, more than half of the components are manufactured, and the Chinese components are transformed into a finished green cartridge. 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) James Forkan Acting Director National Commodity Specialist Division