RE: The country of origin of air tool filters

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365606 October 9, 2026 OT:RR:NC:N1:105 CATEGORY: Origin Icey Huang Autowin Group Limited Flat/RM 08, 15/F Witty Commercial Building 1A-1L Tung Choi Street Mongkok, Kowloon, Hong Kong China RE: The country of origin of air tool filters Dear Ms. Huang: In your letter dated October 1, 2026, you requested a country of origin ruling on air tool filters. Descriptive literature was provided for our review. The first item under consideration is described as a 1/4-inch mini air tool filter (item number 1111200196), which is a compact, point-of-use inline air filtration device specifically designed to attach directly to pneumatic tools (such as impact wrenches, grinders, and spray guns) or air lines via standard 1/4-inch NPT (National Pipe Thread) inlet and outlet ports. Constructed with a lightweight, impact-resistant clear polycarbonate housing, an aluminum alloy cap, and a porous brass element, the unit is designed to trap airborne solid contaminants, such as pipe scale, rust, and dust, and separate moisture, oil, or condensed water from compressed air before it enters the air tool. As compressed air passes through the filter element, particulates are retained, and separated liquid collects at the bottom of the transparent bowl ready to be drained by the valve. The second item under consideration is described as a compact 3/8-inch air filter (item number 1111200194), which is a compact, point-of-use inline air-filtering apparatus designed for installation within pneumatic lines and compressed air systems. It features a 3/8-inch female NPT inlet and outlet porting arrangement to channel air streams directly through a high-efficiency filtration matrix, utilizing a bronze filter element. The filter housing is constructed of an aluminum alloy valve body paired with a transparent polycarbonate bowl and integrated guard, allowing immediate visibility of captured moisture and debris. Operating under pressures ranging between 0 and 150 PSI, the device functions mechanically to intercept, coalesce, and isolate moisture, oil vapor, dust, and rust particles from the compressed air flow before it reaches downstream air tools or pneumatic machinery. The unit is equipped with a standard drain valve at the base of the reservoir cup to evacuate gathered contaminants periodically.
The 1/4-inch mini air tool filter is made from components sourced from China and Malaysia. The Chinese components include the aluminum machining blank (to make the valve body), O-ring, locking collar, filter element, plastic base, screws, springs, retaining ring, filter bowl, and mounting bracket. The Malaysian component is the brass round bar used to make the drain valve core and drain valve seat. The 3/8-inch air filter is made from components sourced from China and Malaysia. The Chinese components include the aluminum machining blank (to make the valve body), O-ring, locking collar, filter element, plastic base, filter bowl, metal protective cover, springs, retaining rings, screws, mounting bracket and locking nut. The Malaysian component includes the brass round bar used to make the drain valve seat, drain valve core and hex lock nut. For both filters, the Chinese components are then sent to Malaysia. In Malaysia, the metal components are constructed using a CNC machining process that starts with precision drilling and deburring and finishes with a final inspection. Once the metal components are made, they are then assembled with the remaining Chinese components to form the complete 1/4-inch mini air tool filter and 3/8-inch air filter. 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 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. 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 should influence 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 the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Based upon your description of the manufacturing operations, we note that a significant amount of the components that comprise the filters are manufactured (CNC machined) in Malaysia. Additionally, these components along with the Chinese O-ring, locking collar, filter element, plastic base, filter bowl, metal protective cover, springs, screws, retaining rings, mounting bracket and locking nut emerge with a new name, character, and use, different from those possessed by the raw materials. Thus, based on the totality of the circumstances, the country of origin of the 1/4-inch mini air tool filter (item number 1111200196) and the 3/8-inch air filter (item number 1111200194) will be Malaysia. 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) James P. Forkan Director National Commodity Specialist Division