The country of origin of a compressor

N361447June 9, 2026OT:RR:NC:N1:102
CATEGORY: OriginNate BolinK&L Gates LLP1601 K Street, N.W.Washington, DC 20006RE: The country of origin of a compressorDear Mr. Bolin:In your letter dated
May 11, 2026
, you requested a country of origin ruling on behalf of your client, MideaIndia Pvt Ltd.The product at issue is referred to as the MI Compressor I. The compressor is an assembly that consists ofupper and lower subassemblies that incorporate various components (a main case, a pump body, a reservoir)and a motor consisting of a rotor and a stator subassembly. The reciprocating hermetic compressor is used inair conditioning systems.With respect to origin, the compressor is assembled in India using components from China and componentsand subassemblies from India.The process to produce the components begins by unwinding the Indian-origin hot-rolled pickling steel sheet stamping machine. tand pressing it using a The steel is then cut or sheared, pressed and then shaped o form lower case and base. fnecking operationthe componentAterwards, and punching s, in sequence, areto reduce the diameter of the partscompleted and to further shape the components. The resulting componentsare used to produce the following subassemblies in India.The uppercase subassembly is comprised of upper case, an a fixing bolt, a terminal block and an exhaustpipe. These components are welded together and subsequently subjected to degreasing and drying processes.Afterwards, a Chinese fixing bolt, an exhaust pipe, and a terminal block are welded and installed onto theupper case.The production of the main case subassembly begins by cutting a Indian steel pipelengthn in , which islright end.Tfollowed by the chamfering of the eft and s Afterwards, the pipe is cleaned and turned. hree holesthe main case pipeare then punched into and a reservoir bracket, and a guide pipe is then welded to the main main case pipe into the expansio diecase pipe. The is then insertedn for adjustments and the main casembly a cleaningand drying .subasseis finalized by undergoing process
The production of the stator core subassembly begins by cutting the insulation paper to length, which isfollowed by a hem process. Next, insulation paper is inserted into a Chinese stator core, and the first windingprocess is completed. The process continues by compressing the wound coil and inserting insulation paper. Asecondary winding is then completed, and the core is further shaped. Afterwards, wire is removed andtrimmed, and the insulation paper is removed using a heating process. Threaded wire with a connector isinserted into its respective slots and then placed into a rotary tying machine to secure the windings and leadwires. In the following step, the lead wire is twisted and brazing is completed. Once complete, a lead wirecover tube is placed over the lead, and an insulation sleeve is placed over the stator subassembly. A thirdshaping process is then completed.The production of the reservoir subassembly begins by cleaning the Indian suction tubes, suction cups andfixing bracket. One side of suction cup B is machined and grooved. A filler is pressed into suction tube Busing a press-fitting machine and a groove is added to the opposite side of suction tube B. The opposite sideof the suction cup is grooved. A brazing process is used to assemble the suction tubes with their designatedsuction cups. A fixing bracket is then added to the subassembly, which is afterwards, buffed, brazed, testedfor air leaks and engraved. Lastly, a cap is installed to seal the reservoir subassembly.The final assembly in India begins by subjecting a Chinese rotor subassembly to a heating process, which isafterwards joined to a Chinese pump body subassembly. A main case subassembly is then heated and oncecooled it is integrated into the case thermal sleeve, and the main case subassembly is welded to the statorsubassembly. During the next step, a copper head is manually installed and welded in position, which isfollowed by the assembly of the lower and upper cases onto the main case and the attachment of a Chineseterminal pad. The base subassembly, along with the lower case and the main case subassembly, are thenplaced on the upper electrode plate to complete the base welding process. Subsequently, a reservoirsubassembly is installed, and a reservoir clamp is installed. Afterward, a guide and taper pipe are welded inplace and then Chinese sealing plugs are placed on the exhaust and the suction pipes of the reservoirsubassembly. Lastly, the compressor is coated, pre-treated, painted and filled with refrigerant oil and injectedwith nitrogen. Inspections and testing are completed throughout the various processes.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 (HQ)Ruling Letter H301619, dated November 6, 2018. The test for determining whether a substantialtransformation will occur is whether an article emerges from a process with a new name, character, or usedifferent 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 HandTool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).Here, subassemblies are produced in India and then combined with a motor (stator and rotor subassemblies).This scenario is similar to an origin scenario CBP previously reviewed in HQ Ruling Letter H326072, datedJanuary 25, 2024, in which CBP relied on the origin of the motor of the compressor. In this instance, theorigin of the motor of the subject compressor assembly has been considered and is determined to be India.Therefore, as the origin of the motor for the subject is India, the origin of the compressor assembly is India.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 andcomplete 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