The country of origin of a coil indoor unit

N360640May 11, 2026OT:RR:NC:N1:102
CATEGORY: OriginNate BolinK&L Gates LLP1601 K Street, N.W.Washington, DC 20006RE: The country of origin of a coil indoor unitDear Mr. Bolin:In your letter dated
April 12, 2026
, you requested a country of origin ruling on behalf of your client, MideaIntelligent Manufacturing (Thailand) Co., Ltd. to apply current trade remedies and for marking purposes.The product at issue is an MIT A Coil Indoor Unit, model number MCPM3036BM10OH. The coil indoorunit consists of a cabinet that primarily encases an evaporator, a chassis assembly, a valve assembly, asteel drain pan, and a gas sensor. In use, the unit must bepaired with an outdoor condenser unit and a gas furnace a traditional split system. The indoor unit canto complete air conditioning that cools and dehumidifies spacesalso be paired with an air handler that consists of a blower motor and a fan.With respect to origin, the final assembly of the coil indoor unit occurs in Thailand using components fromThailand and China. Prior to the final assembly, the evaporator subassembl and structural panels areyproduced in Thailand.The evaporator subassembly, which is configured in the shape of the letter A, consists of two evaporatorcoils, an outlet pipe, a junction board, a valve core and a waterproof board. The assembly process of thissubassembly begins by applying oil to aluminum foil, which is followed by the manufacturing of fins using apressing machine. Afterwards, the stamped fins are configured into an appropriate configuration using aU-shaped pipe bending machine, in which cutting, straightening and bending processes are completed. Oncethis step is complete, the U-shaped tubes are inserted through the fins and manually positioned into theevaporator clapboards, which is followed by an expansion process that bonds the fins to a coil. The secondevaporator clapboard is assembled to the fin stack manually, a drying process is completed using an oven andthe evaporator coil undergoes a melting process to melt the solder, bonding the semi-circular pipes and thecoil. Afterwards, repair welding is completed as needed. Next, an outlet pipe is welded in place, and a valvecore and rubber plug are welded into the inlet and outlet pipe assemblies, which is followed by theinstallation of a gas sensor onto the fixing board. The two evaporators are then positioned and screwed in
place. Subsequently, the junction and water boards are installed and secured onto the evaporator along withthe waterproof board. Lastly, a sponge is installed in place, and the finished evaporator subassembly isinjected with gas.Three boards (waterproof, fixing and drainage pan supporting board), three different platesstructural s(fixing, mounting and evaporator connecting), support bars, and side pane are formed using a a pipe cover ls bending process. As needed, a sponge is installed onto the chassis,mechanicaltouch welding is completed, and a coating is appliedubber seals onnection points.. For the pipe cover, rare installed onto thecThe final assembly begins by bolting the right and leftadhering foil paper from China to the air outlet and drainage pan supporting boardstfixing plates onto the chassis. Subsequently, a mounting plate, along with he and waterproof board are secured in position using screws. Next, two drain pans are inserted into theevaporator assembly, which is afterwards transferred onto the chassis and clipped into the fixing bars. In theusing screws.Lastly, a pipe cover and following step, a drainage pan board and a support bar are secured the side panels are screwed in place to complete the cabinet. Each unit is subjected to tests and inspections, andafterwards labeled and packaged with a bag containing accessories.When determining the country of origin for purposes of applying current trade remedies under Section 301and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters RulingLetter H301619, dated November 6, 2018. The test for determining whether a substantial transformation willoccur is whether an article emerges from a process with a new name, character, or use different from thatpossessed 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).Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unlessexcepted, every article of foreign origin imported into the United States shall be marked in a conspicuousplace as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such amanner as to indicate to the ultimate purchaser in the United States, the English name of the country of originof the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should beable to know by an inspection of the marking on the imported goods the country of which the goods is theproduct. 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 shouldinfluence his will.” See United States v. Friedlaender & 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 thecountry of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBPRegulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, orgrowth of any article of foreign origin entering the United States. Further work or material added to an articlein another country must effect a substantial transformation in order to render such other country the “countryof origin” within the meaning of the marking laws and regulations.In this instance, the final assembly processes that occur in Thailand are not complex. The evaporatorsubassembly and the remaining components are simply inserted into the cabinet and screwed in place. Thecomponents do not lose their individual identities to become an integral part of a new article, possessing anew name, character and use. We believe the origin of the indoor unit should be determined by its dominantcomponent, which is the component that contributes to the cooling cycle, i.e., the Thai evaporator. As such,the country of origin of the subject indoor unit is Thailand.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation 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 notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Sandra Martinez at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division