The country of origin of automotive air conditioning filters

N353723
September 30, 2025
OT:RR:NC:N1:105
CATEGORY: Origin Pitchaya Pradbkaew QAP Filter (Thailand) Co., Ltd. 98/3 Moo 11, Nongbua, Bankhai Rayong 21120 Thailand RE: The country of origin of automotive air conditioning filters Dear Ms. Pradbkaew: In your letter dated September 15, 2025, you requested a country of origin ruling on automotive air filters. Descriptive literature was provided for our review. 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 filters are usually located behind the glove compartment or under the dashboard. The WT312021C and WT321043C models are rectangular versions of the filter with a frame holding the filtering material in place. The automotive air conditioning filter is assembled in Thailand using components from Thailand and China. The Chinese components include the frames, hot melt adhesive, gasket, color box and label. The Thai components include the functional element, filter media, blister film, instruction manual, and other packaging materials including the box, pallet, cardboard and paper angle bead. The assembly process occurs entirely in Thailand and includes seventeen steps. The process starts with the slitting of the non-woven fabric raw material using a slitting machine, followed by a media pleating machine fold line pressing and media pleating the fabric. Next, the functional element is shaped using a heat curing machine. A worker then manually cuts the media from a three-dimensional filter block into small filter blocks of equal volume using a slitting knife. The media is then processed for self-sealing using an ultrasonic welding machine. Next, a bevel cutting machine cuts the element before the filter media is brought to an adhesive injection machine to apply the back gum. The filter forming process continues with flash trimming, gasket bonding, and spraying the 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 filter, it is our opinion that the manufacturing and assembly process performed in Thailand is considered complex. In this instance, the primary filtering components, including the paper from China and the media from Thailand, need to be ultrasonically combined in Thailand. In our opinion, while many of the additional steps include simple assembly, the ultrasonic combining creates a new article with a new name, character, and use. Therefore, in our opinion, the country of origin of the WT312021C and WT321043C automotive air conditioning filters is Thailand, which is where the fiber base paper and filter media is ultrasonically combined. 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 Designated Official Performing the Duties of the Division Director National Commodity Specialist Division