The country of origin of automotive air filters

N352595
September 5, 2025
OT:RR:NC:N1:105
CATEGORY: Origin Yuting He QAP Automotive Industries (China) Ltd. No. 851 Chengzhong Road, Fengcheng Town, Fengxian District Shanghai 201400 China RE: The country of origin of automotive air filters Dear Yuting He: In your letter dated August 19, 2025, you requested a country of origin ruling on automotive air filters. The items under consideration are described as automotive air filters, which are components of the automotive heating, ventilation, and air conditioning (HVAC) system designed to clean the air entering the vehicle’s interior. The devices filter out dust, pollen, mold, bacteria, and other airborne particles, improving the air quality inside the car. The filter is usually located behind the glove compartment or under the dashboard. The WT215064UNX and WT215041NX models are rectangular versions of the filter with a frame holding the filtering material in place. The automotive air conditioning filters are assembled in China using components from Korea and China. The Chinese components include the filter element (structural support and housing for the media), slitted media block, sealing adhesive, metal mesh, polyether polyol, isocyanate, and some of the packaging including the color box and labels. The filter media is from Korea. The assembly process occurs entirely in China and includes seventeen steps. The process starts with the humidification of the media material, followed by flow-channel shaping of the raw material using press roller machines. After the material is shaped, an adhesive injection machine is used to internally seal the filter material together. A media pleating machine folds or pleats the filter media for the next step, shaping the filter element by utilizing a cooling channel. A worker then manually cuts the media using a slitting knife in preparation for the metal mesh bonding step, a semi-automatic process undertaken by a gluing machine. Once glued, a polyurethane (PU) tooling heating process prepares the pleated filter media for adhesion to the rigid structure of the filter. Next, the filter media is brought to a two-component adhesive injection machine where A (polyol) and B (isocyanate) PU adhesives are mixed to initiate a chemical reaction to create a strong, durable bond and rigid structure that is used to fix the pleated filter media within the frame. The filter

forming process continues with the application of PU foam, element heating, flash trimming, pleating stabilization adhesive injection, and spraying data code. Finally, the filter is wrapped in plastic using a laminating machine and sent along a conveying line for placement and packing in a cardboard box. 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 filters, it is our opinion that the manufacturing and assembly process performed in China is not considered complex. In this instance, the Korean filter media is the primary filtering component of the finished filters and is the most expensive portion of the finished product. While the media is pleated in China, it does not become a new article with a new name, character, and use. Therefore, in our opinion, the country of origin of the WT215064UNX and WT215041NX automotive air conditioning filters is Korea, which is where the filter media 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) Denise Faingar Acting Director National Commodity Specialist Division