The country of origin of an air compressor assembly

N362856
August 4, 2026
OT:RR:NC:N1:102
CATEGORY: Origin Austin Corbin Red River Sourcing 808 Equestrian Drive Soddy Daisy, TN 37379 RE: The country of origin of an air compressor assembly Dear Mr. Corbin: In your letter dated July 5, 2026, you requested a country of origin ruling on behalf of your client, Kaishan Compressor USA. The product at issue is referred to as the KRSD Series air compressor. The compressor is an assembly that consists of various components: an outer housing (a base frame and panels), an air/oil separator tank, a cooling mechanism, an electrical system, piping assemblies, and a motor. The air compressor is used in air conditioning systems and has an output range of 15-200 horsepower. With respect to origin, the air compressor is assembled in Turkey using components primarily from China, motors from Brazil and few a components sourced from Turkey. The final assembly begins by installing an oil return pipe to a top cover, followed by the mounting and adjustment of a cover plate. Next, a safety valve, a pressure gauge, and an oil observation window are installed, and shock absorbers are bolted to a base frame from Turkey. An airend assembly is then bolted to the exterior of the chassis. Subsequently, a motor support bracket, bracket mountings, a coupling, a flange, and a motor adapter are installed onto a Brazilian motor, which is then bolted to a screw block. The process continues with the installation of a transmitter, fittings, pipes, and a regulating valve. The suction valve gasket and valve are secured to the airend using a nut and spring, followed by the installation of a flexible air duct and gasket. Thin pipes from a Turkey-sourced tank are then connected, sealed, and bolted to the suction, control, and discharge valves. Additionally, a drain line hose, nipples, and O-rings are installed onto a cooler, a fan, and a radiator, followed by the installation of hoses onto a thermal valve. Air outlet connection pipes and nipples are connected and covered with a protective cap. A fan top cover is rotated, and fan blades featuring a motor from Brazil are installed. To complete the compressor, outer panels and a door from Turkey are bolted in position, and the electrical connections are finalized. Finally, a top cover and air filter hose are installed, adhesive is applied, and the finished compressor is labeled, packaged, and ready for shipment.

When determining the country of origin for purposes of applying current trade remedies under Section 301 and 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 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). In HQ Ruling Letter H326072, dated January 25, 2024, CBP considered the origin of a similar compressor assembly, consisting of a compressor and a motor, and determined the country of origin for a compressor assembly based on the origin of its motor. Therefore, as the motor of the subject compressor assembly is of Brazilian origin, the origin of the subject compressor assembly will be Brazil. 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 Sandra Martinez at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division