The country of origin of water purifiers

N361552June 5, 2026OT:RR:NC:N4:410
CATEGORY: OriginXiaolei LiuMidea Kitchen and Water Heater Manufacturing (Thailand) Co., Ltd.386/56 Moo 2, Khao Khansong Sub-DistrictSriracha District, Chonburi ProvinceSriracha 20110ThailandRE: The country of origin of water purifiersDear Mr. Liu:In your letter dated
May 15, 2026
, you requested a country of origin ruling for the purposes of applyingcurrent trade remedies.The merchandise under consideration is referred to as Platform D and Platform T Water Purifiers (the “waterpurifiers”), which are electric hot and cold water dispensers. The models subject to this request are composedof a water source such as a refillable bottle, an internal multi-stage filtration system, a heating and coolingsystem, and a dispensing mechanism. The water purifiers are powered by electricity, allowing each to filter,heat, or chill the water as needed. Differences between the two platform models of water purifiers are limitedto minor variations in exterior design and control panel layout. Both are similar in core functionality, internalcomponent structure, and manufacturing quality. With the exception of the final assembly process, themanufacturing process for each water purifier platform in Thailand are identical. In your request, you illustrate that the water purifiers would be assembled in Thailand with componentssourced from China and produced in Thailand. The components sourced from China are the cold water tanks,compressors and temperature controllers. The factory in Thailand will produce the balance of thecomponents, i.e., power cords, evaporators, and hot water tanks, and then combine these components with theChina-origin components to make the finished products. The manufacturing process in Thailand includes theoperations of metal cutting, forming, bending, stamping, and welding.You further explain that the manufacturing process of water purifiers in Thailand can be divided into threemajor stages. The total process requires anywhere from 90 to 110 workers over 50 distinct steps, whichincludes critical operations such as bending, welding, stamping, assembly, fastening, and testing. Each steprequires heavy machinery and equipment to ensure precision and adherence to design specifications. Thethree main processing stages are described as follows:
1. Manufacturing of Key Components in ThailandKey water purifier components are manufactured in Thailand using steel, copper, and aluminum materials.The condenser, evaporator, and hot tank undergo specialized processes such as tube bending, resistancewelding, stamping, and component assembly using heavy machinery and welding equipment. Each partfollows a defined sequence to meet structural and performance standards, with 7 to 15 workers assigned percomponent line. These operations ensure durability, precision, and consistency across all units.2. Subassembly Processes in ThailandAfter producing key components, subassemblies for the water purifier are assembled in Thailand. The frontshell subassembly involves installing the spout, display, faucet, and fixing block using screws to ensurealignment and structural integrity. The hot tank subassembly includes mounting sensors, wiring the faucet,and securing the tank and silicon pipe to the support frame. The cold tank subassembl involves attaching theevaporator, gluing the sponge, fastening the tank to the supporter, and performing bending operations. Eachsubassembly is constructed using specialized tools to meet design and functional standards.3. Final Assembly & Testing in ThailandIn the final stage, workers complete the water purifier assembly in Thailand using subassemblies andadditional components. The process includes securing structural parts suah as the base, tanks, valve, andcompressor, followed by electrical wiring and refrigerant charging. Leak detection is performed using halideand leakage test machines, and safety tests ensure compliance with operational standards. Final steps includeassembling covers, applying labels, and conducting visual inspections. Units are then packaged usingprotective materials and cartons, ensuring each product meets quality and safety requirements beforeshipment.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).This office reviewed the provided assembly process descriptions and is of the opinion that the factory inThailand produces a significant a number of components, including key components, from plastic, steel,copper, and aluminum raw materials; the non-Thai origin components undergo enough of a change toafterwards emerge with a new name, character, and use that is different from what they possessed prior toprocessing, thus completing a substantial transformation. ,Accordingly we agree that the country of origin forurposes of applying the current trade remedies.the water purifiers at issue is Thailand for the pThe 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 Michael Chen at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division