The country of origin of an automotive air filter

N351081
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 an automotive air filter Dear Ms. Prachakool: In your letter dated July 8, 2025, you requested a country of origin ruling on an automotive air filter. Descriptive literature was provided for our review. The item under consideration is described as an automotive air filter, which is an automotive component designed to clean the air that enters a vehicle’s engine and cabin. It acts as a barrier, trapping dirt, dust, and other contaminants to prevent them from reaching the engine’s sensitive internal parts or the passenger compartment. The automotive air filter is replaced by opening the plastic housing above the engine (typically located behind the glove box). The automotive air filters are assembled in Thailand using components from Thailand and China. The Thai components include the paper mesh components, paper blocks, and some of the packaging that includes corner protectors, cardboard, a pallet, and an outer box. The Chinese components include the filter paper, origami glue, metal mesh, polyether polyol, isocyanate, and some of the packing material that includes the paper box and labels. The assembly process occurs in Thailand and includes ten steps. The process starts with the origami, which is made on a reciprocating origami machine. Next, the paper is folded before glue and metal mesh is added. Then, the PU foam is added and trimmed. Next, the cotton sponge is glued and applied prior to spray coding, plastic sealing, and final packaging. 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 automotive air filter, it is our opinion that the manufacturing and assembly process performed in Thailand is not considered complex. In this instance, the Chinese filter paper is the primary filtering component of the finished filter. While the paper is pleated in Thailand and a few other minor components are added, the paper does not become a new article with a new name, character, and use. Therefore, in our opinion, the country of origin of the automotive air filter is China, which is where the filter paper 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) James Forkan Acting Director National Commodity Specialist Division