The country of origin of a water purifier

N351887
August 18, 2025
OT:RR:NC:N1:105
CATEGORY: Origin Jamie Smith Amway 7575 Fulton Street East Ada, MI 49355 RE: The country of origin of a water purifier Dear Ms. Smith: In your letter dated July 31, 2025, you requested a country of origin ruling on a water purifier. Descriptive literature was provided for our review. The item under consideration is described as the eSpring Water Purifier, which is a device that filters and disinfects water as part of a two-step purification process. There are three primary subassemblies in the system including the filter subassembly, ultraviolet (UV) subassembly, and electronics module subassembly. The filter and UV subassemblies sit in separate cylindrical housings, one adjacent to the other. The eSpring Water Purifier starts by allowing water to enter the unit and passes through the filter subassembly featuring a carbon block filter media that removes contaminants through adsorption. After passing through the filter, the water is subsequently treated by a UV subassembly that disinfects the water by killing any residual microorganisms using UV LED lights. The electronics module performs the ancillary functions of providing power to the UV subassembly and controlling the visual and audible status indicators on the display. The e3 carbon filter removes 170 plus contaminants from the water, while the UV-C LED technology removes remaining microorganisms. The eSpring Water Purifier consists of a filter subassembly and a flow sensor subassembly of U.S. origin, and a UV tank subassembly of Japanese origin. The Chinese components include a radio frequency identification (RFID) printed circuit board assembly (PCBA), a frame sub-assembly, tank, tank lid, and an electronic module sub-assembly. Various hardware and additional materials (plastic parts, screws, and labels) are also of Chinese origin. The U.S. origin filter subassembly is a 5-step process that takes 6 people to assemble. It contains the carbon block that is sourced exclusively from the U.S. The carbon block is the most expensive component and is the primary device performing the water filtering. This filter is designed to be replaced yearly based on its heavy use and function. The Japanese-origin UV subassembly is a 14-step process that includes multiple functional testing steps and takes 13 people to complete. It is designed to kill microorganisms after the water has been passed through the filter subassembly. The Chinese-origin electronic module subassembly is a 22-step

process that takes 17 people to assemble. The electronic module is assembled in China with 236 separate electronic parts. The final 8-step assembly process occurs in China and involves pressing and snapping together the three subassemblies and additional components into position by hand and fastening together with screws. The 10-member crew starts with the first step, which includes attaching the UV system to the frame assembly. Then the workers attach tubing from the flow sensor to the UV system with clamps. The second step requires placing the RFID PCBA board and electronic module assembly into the tower assembly. In the third process the operator installs the filter subassembly into the filter tank. The fourth step places the filter inside the filter tank, attaches and torques the lid into place, and installs the filter assembly inside the tower assembly. The fifth step involves laser printing the identification label to the back panel and attaching it to the tower assembly. The sixth station operator screws the back cover plate to the tower assembly before the testing and final packaging. Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (CBP) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. A substantial transformation occurs when, as a result of the manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). Regarding the origin of the eSpring Water Purifier, the assembly process in China 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 eSpring Water Purifier, 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 eSpring Water Purifier 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) James Forkan Acting Director National Commodity Specialist Division