Country of Origin of Air Purifiers; Substantial Transformation

H323218 December 16, 2025 OT:RR:CTF:FTM H323218 MD/TJS CATEGORY: Origin Mr. Sydney H. Mintzer Mayer Brown LLP 1999 K Street, NW Washington, DC 20006 Re: Country of Origin of Air Purifiers; Substantial Transformation Dear Mr. Mintzer, This is in response to your correspondence, dated January 31, 2022, requesting reconsideration of two New York Ruling Letters (“NY”) issued by U.S. Customs and Border Protection (“CBP”), regarding the country of origin of air purifiers on behalf of your client, Lasko Products, LLC (“Lasko”) and its related company, Guardian Technologies, LLC (“Guardian”). Specifically, CBP issued NY N322364 to Guardian on November 18, 2021, determining that the country of origin of the air purifier was either Vietnam or China dependent on the presented manufacturing scenarios. On December 1, 2021, CBP issued NY N322681 to Lasko, determining that the country of origin of the air purifier was China under both of the presented manufacturing scenarios. We have reviewed both NY N322364 and NY N322681 and have determined them to be in error for the reasons set forth herein. Pursuant to section 625(c)(1), Tariff Act of 1930 (19 U.S.C. § 1625(c)(1)), as amended by section 623 of Title VI (Customs Modernization) of the North American Free Trade Agreement Implementation Act (Pub. L. 103-182, 107 Stat. 2057), notice proposing to modify NY N322364 and revoke NY N322681 was published on October 12, 2022, in Vol. 56, No. 40 of the Customs Bulletin. No comments were received in response to the notice. FACTS: In NY N322364, the air purifier at-issue was described as follows: The merchandise under consideration is identified as Germguardian AC4825E 4 in 1 Air Purifying System (the “Air Purifier”). The subject air purifier, roughly cylindrical in shape with a control panel on top, is a device that uses a fan, a carbon fiber, [High Efficiency Particulate Air (“HEPA”)] filtration and [Ultraviolet-C (“UV-C”)] Light Technology to trap allergens, fight germs and reduce unpleasant odors. The air purifier removes dust, pet dander and pollen. The air purifier within NY N322681 was similarly described as: The merchandise under consideration is an air purifier described as the GermGuardian Elite 5-in-1 Air Purifier with Pet Pure (model No. AC4300BPTCA). The device utilizes a fan, a UV-C light, a carbon pre-filter[,] and a HEPA filter to help remove allergens from the air. The HEPA filter captures 99.7% of particles like pet dander, dust mites[,] and pollen. The carbon filter reduces common odors from pets, smoking[,] and cooking. The UV-C light helps reduce airborne bacteria, viruses, mold spores[,] and works with Titanium Dioxide to reduce volatile organic compounds. It is recommended that the HEPA filter be replaced every 6-8 months, depending on the use, indicated by the filter change indicator. The dimensions are 8.88” x 6.38” x 22” and is recommended for use in rooms up to 153 square feet. In both NY N322364 and NY N322681, two manufacturing scenarios were presented for each of the air purifiers. The manufacturing scenarios discussed within NY N322364 were detailed, in pertinent part, as follows: In the first scenario, the UV lamp, UV lamp holder and protection board, [Printed Circuit Board (“PCB”)] assembly [(“PCBA”)], fan switch, motor switch assembly, HEPA filter, air outlet iron net, and power cord, etc. are imported from China. All other components and parts are manufactured in Vietnam. They include the plastic molding parts (UV lamp box and cover, top cover, cap of top cover, control panel, button and knob, front cover and rear housing, rear cover, blower, blower covers, motor bracket, PCB box, switch covers), motor, screws in addition to labels, packing materials, etc. The Bill of Materials indicates that approximately 56% (by value) of the components and parts used to produce the Air Filter are made in Vietnam. The production process in Vietnam consists of both the production of the sub- assemblies/parts with the Vietnamese originated and imported components and materials, and the final assembly process. […] The following sub-assemblies/parts are made in the manufacturing process before and for the final assembly process in the Vietnamese factory: the control panel (39 steps), UV lamp assembly (19 steps), PCB assembly (4 steps), decorative lamp strip (11 steps), wire/terminal preparation (7 steps), rotary switch assembly (3 steps), UV protective board processing (4 steps), microswitch PCBA installation (17 steps), motor assembly installation (17 steps), rear shell/housing assembly (49 steps). The final assembly process is to use the above sub-assemblies/parts made in the Vietnamese factory to manufacture the finished air purifiers. The final manufacturing process includes: inspecting the plastic molded front housing (4 steps), installing the iron outlet to the front housing (4 steps), shaping and affixing iron outlet locking foot in the machine (4 steps), installing the motor compartment (3 steps), affixing the motor bracket to the front housing (2 steps), affixing the air duct to the front housing (3 steps), connecting the top control panel (6 steps), installing UV lamp components (8 steps), 2 installing the PCB box (4 steps), installing the PCB fireproof box (4 steps) installing top housing (2 steps); installing the top cover (3 steps), affixing the UV lamp to the front housing (3 steps), connecting the front and rear housing wires (6 steps), assembling the front housing and rear housing and installing the UV (10 steps), securing the top cover and UV lamp protection board (4 steps), and affixing the filter to the rear housing (6 steps). The second manufacturing scenario is similar to the first one presented but the motor will be imported from China instead of being made in Vietnam. Accordingly, the portion of Vietnamese originated components and parts will decrease to approximate 35% (by value) in this scenario. In NY N322681, the manufacturing scenarios are discussed, in relevant part, as: In manufacturing scenario 1 numerous components are purchased in China including the HEPA filter, motor assembly, light assembly, PCB[A], power cable, starting capacitor, most UV lamp parts[,] and the color carton for packaging. The PCB[A] is purchased in China as a complete assembly and is loaded with Chinese firmware containing product controls and safety features. The functions of the PCBA are to turn on/off the machine and UV lamp, control the working speeds, the timer for the UV and HEPA working time, and the UV and HEPA replacement reminder. The HEPA filter is composed of a plastic frame, PU foam, hot melt glue, tape, white non-woven fabric as well as anti-bacterial and antiallergic non-woven fabric. These Chinese-origin materials are shipped to Vietnam for assembly into finished air purifiers. There is no assembly work done at the factory in China except for some minor assembly of the wiring. The processes done at the Chinese factory include inspections, testing, and handling of purchased components. […] The remaining parts will be manufactured in Vietnam including the housing components, fan, motor frame, control panel, PCB box, brackets and switches, screws and fasteners, Microswitch boxes; and packaging components such as labels, product manual and brochure, paper pallets, and bags. […] The assembly process in Vietnam includes the following steps: Unpack and combine the front cover components, attach the decorative lamp component, and lock fixing the frame. The next steps involve installing the motor assembly, place air duct cover, and attach motor brackets. This is followed by attaching the air duct cover, aligning and installing the UV lamp (including plugging in the terminals), rear housing assembly (inserting terminal wires, plug terminal and apply glue), fix the voltage-reduce capacitor, fix the top cover, align and combine the front and rear covers, fix the rear housing, and install the filter. The final processes include packing the air purifiers, applying logos and labels, and sealing the box. Installation of each of the Chinese assemblies (including microswitch, UV lamp, rear housing, decorative lamp, top cover, motor and light) involve several steps which include plugging in devices, screwing, gluing, and manipulation of wires (separating, straightening, or twisting). The overall production process in Vietnam will involve 94 workers and inspectors and take approximately 64 minutes to assemble the electrical and non-electrical components into each air purifier. 3 In [manufacturing scenario 2], additional components made in China are sent to Vietnam for final assembly of the air purifier. Additional components sourced in China include the top and bottom fan housing, fan, switch boxes, frames, control panel, brackets, and switches. Within your request for reconsideration, you clarify that, “[f]or both models, the motor, along with the HEPA filter, UV lamp and lamp holder, PCBA, power cord/cable, wire, start capacitor, microswitch, UV protection board, and color cartons are imported from China.” In the production of the GermGuardian AC4300BPTCA Elite 5-in-1 Air Purifier (“Model AC4300”), you note that the “UV lamp box, lamp cover, and lamp ring subassembly are also sourced from China.” In the production of the GermGuardian AC4825 4-in-1 Air Purifying System (“Model AC4825”), you note that the “connecting rod, fan speed switch, iron net for the air outlet, and anti-theft strip are also sourced from China.” These above components are all “shipped in bulk to Vietnam for use in assembly of subassemblies and the finished air purifier.” Furthermore, you elaborate that there are several components utilized in the manufacture of both air purifiers that a “fully sourced in Vietnam.” Specifically, you state that “all plastic components, including the fan blade, fan housing, housing components, control panels, switch covers, PCBA box, holders/brackets, and the control buttons and knobs” are all injection-molded in Vietnam. Alongside these plastic components, you note that the control panel, UV lamp assembly, PCB assembly, decorative lamp strip, wire/terminal preparation, rotary switch assembly, UV protective board processing, microswitch PCBA installation, motor assembly installation, and rear shell/housing assembly are all manufactured in Vietnam prior to the ultimate assembly of either air purifier. You highlight that the motor subassembly is also produced in Vietnam; from a Chinese-origin basic motor which is secured into the motor bracket and attached with plastic fan blades and fan housings. Finally, you emphasize that these Chinese-origin basic motors used in the production of the motor subassembly are capable of use in a number of devices, including various small appliances, such as fans and heaters, in addition to air purifiers. You contend that the combination of this Chinese-origin basic motor with electronic components and fan blades, as well as the further combination of the various sub- assemblies via installations, connections, and inspections substantially transforms the basic motor – which cannot move, filter, or purify air in its original state – into the finished air purifier. ISSUE: What is the country of origin marking of the air purifiers? LAW AND ANALYSIS: 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 4 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.” United States v. Friedlander & Co., 27 C.C.P.A. 297 at 302; C.A.D. 104 (1940) (emphases added). Part 134, U.S. Customs and Border Protection (“CBP”) Regulations (19 C.F.R. Part 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. § 1304. Section 134.1(b) defines “country of origin” as: [T]he 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 regulations]… A substantial transformation is said to have occurred when an article emerges from a manufacturing process with a name, character, and use which differs from the original material subjected to the process. United States v. Gibson-Thomsen Co., 27 C.C.P.A. 267, C.A.D. 98 (1940); Texas Instruments, Inc. v. United States, 681 F.2d 778, 782 (1982). In determining whether the combining of parts or materials constitutes a substantial transformation, the determinative issue is the extent of the operations performed and whether the parts lose their identity and become an integral part of the new article. Belcrest Linens v. United States, 6 CIT 204, 573 F. Supp. 1149 (1983), aff’d, 741 F.2d 1368 (Fed. Cir. 1984). If the manufacturing or combining process is a minor one that leaves the identity of the imported article intact, a substantial transformation has not occurred. Uniroyal, Inc. v. United States, 3 CIT 220, 542 F. Supp. 1026 (1982), aff’d, 702 F.2d 1022 (Fed. Cir. 1983). In order to determine whether a substantial transformation occurs when components of various origins are assembled into completed products, CBP considers the totality of the circumstances and makes such determinations on a case-by-case basis. The country of origin of the item’s components, extent of the processing that occurs within a country, and whether such processing renders a product with a new name, character, or use are primary considerations in such cases. No one factor is determinative. NY N322364 (GermGuardian AC4825 4-in-1 Air Purifying System) NY N322364 discussed two manufacturing scenarios for Model AC4825. In the first manufacturing scenario, the UV lamp, UV lamp holder and protection board, PCB assembly, fan switch, motor switch assembly, HEPA filter, air outlet iron net, and power cord were imported from China. All other components are parts – including the plastic molded parts (UV lamp box and cover, top cover and cap, control panel with buttons and knobs, front and rear covers, rear housing, blowers, blower covers, motor bracket, PCB box, and switch covers), motor, screws, and labelling/packing materials – were manufactured in Vietnam. The bill of materials indicates that approximately 56% by value of the components and parts used in this manufacturing scenario were made in Vietnam. The second manufacturing scenario is virtually identical to the first manufacturing 5 scenario except for one difference; the motor utilized in the second manufacturing scenario is imported from China as opposed to being manufactured in Vietnam. As such, the bill of materials for the second manufacturing scenario indicates that approximately 35% by value of the components and parts were made in Vietnam. In NY N322364, CBP found that the country of origin of the Model AC4825 was either Vietnam, under the first manufacturing scenario, or China, under the second manufacturing scenario. Specifically, CBP found that “the processing in Vietnam with respect to the [a]ir [p]urifiers in the first scenario does constitute a substantial transformation of the imported components and parts into ‘products of’ Vietnam.” Regarding the second manufacturing scenario, CBP elaborated that no such substantial transformation had occurred because the Chinese-origin “motor is such a significant component in making the air purifiers at issue and also the most expensive component of the air purifiers.” Therefore, CBP determined the country of origin of the Model AC4825 as either Vietnam or China, based on the motor’s origin. Upon further review of the manufacturing processes presented, we find that the Model AC4825 is a product of Vietnam, regardless of whether its component motor is sourced from Vietnam or China. As detailed, the origin of the component motor is the only discernable difference between the two manufacturing scenarios. In both scenarios, several components are fully sourced from Vietnam. These include all plastic components, such as the fan blade, fan housing, housing components, control panels, switch covers, PCBA boxes, holders and brackets, and all control buttons and knobs. The Vietnamese-origin, injection-molded components are combined with each other and Chinese-origin components in Vietnam to produce various sub- assemblies, including the control panel, UV lamp assembly, PCB assembly, decorative lamp strip, wire/terminal preparation, rotary switch assembly, UV protective board processing, microswitch PCB assembly, and the motor/fan assembly. These various sub-assemblies are then further assembled in Vietnam into the finished Model AC4825. We find that the manufacturing scenarios here, involving components of differing origins which are combined into sub-assemblies and ultimately processed into a finished product, are similar to those from prior CBP rulings. One such ruling, elaborated within your request for reconsideration, is Headquarters Ruling Letter (“HQ”) H303177, dated May 4, 2020. Within HQ H303177, CBP contemplated the manufacturing scenarios of an air purifier and determined its country of origin. Specifically, HQ H303177 considered two manufacturing scenarios of an air purifier which involved the importation of Chinese-origin electric components, including a motor, and other packaging materials into Indonesia, where they are assembled with Mexican- origin filters and Indonesian-origin components into the finished product. In the first manufacturing scenario, “Mexican filters and components from China, including the fan, motor, and electronic components [were] shipped to Indonesia [for assembly] with Indonesian plastic components into finished air purifiers.” Indonesian operations in the first manufacturing scenario also included “the subassembly of ‘small parts,’ further processing of certain parts, and the manufacture of the majority of plastic components including the housing components, control panels, switch covers, switch boxes, handles, and brackets.” CBP found that these Indonesian assembly operations, consisting of “injection-molding 6 the plastic parts, installing major components and subassemblies, testing, and packaging, are sufficiently complex and meaningful as to substantially transform the non-originating components.” CBP also noted that the plastic components, which were assembled together in Indonesia to for the housing and exterior elements during the subassembly stage, were an “integral part of the finished device’s character and use because they form the structure and appearance of the device.” Ultimately, CBP held that the character of the finished air purifier differed from that of the imported materials because the Chinese-origin components lost their individual identities and became an integral part of a new article when assembled with the Indonesian components and Mexican filters in Indonesia. Accordingly, CBP found that the air purifiers in HQ H303177 were products of Indonesia under the first manufacturing scenario. In the second manufacturing scenario, “the main plastic components, including the housing, control panel, switch covers/boxes, handles, and brackets [were] injection-molded in China and then shipped to Indonesia for assembly with the other Chinese-origin parts and Mexican filters.” Notably, the only components manufactured in Indonesia, in the second manufacturing scenario, were packaging materials and parts ancillary to assembly, such as screws, washers, and wiring caps. CBP noted that the determinative question at-hand was “whether the assembly operations in Indonesia [were] complex and meaningful enough to substantially transform the imported components.” In the second manufacturing scenario, CBP re-elaborated that “the plastic components are integral to the character and use of the air purifier” and stated that the whole console – assembled from the “plastic components” and other “Chinese-origin parts,” is a “complete device, identifiable as an [air purifier].” As the “console alone provides the fundamental structure, appearance, and capacity to operate,” CBP found that the console “distinguished the final product as a household air purifying device.” While CBP noted that the “console’s primary parts (the plastic components, fan, motor, and electronic components),” were of Chinese-origin, it found that the overall production process in Indonesia transformed the electrical and non- electrical components into a completed air purifier. As such, CBP found that the air purifiers in HQ H303177 were also products of Indonesia in the second manufacturing scenario. Additional CBP rulings concerning the country of origin of vacuum cleaners support the ultimate determination that the country of origin of the Model AC4825 air purifier is Vietnam. In NY N324519, dated March 23, 2022; NY N322606, dated November 23, 2021; NY N322549, dated November 5, 2021; and NY N319176, dated May 19, 2021; CBP found that the country of origin of subject vacuum cleaners was Vietnam. Each of the vacuum cleaners underwent manufacturing in Vietnam from Chinese and Vietnamese-origin parts and components. Notably, the motor assembly utilized in each of the manufacturing processes was of Chinese-origin. In Vietnam, the Chinese and Vietnamese-origin parts and components were used to make five distinct sub-assemblies – the dust cap sub-assembly, the floor brush sub-assembly, the nozzle sub-assembly, the handle hose sub-assembly, and the body sub-assembly. The final assembly consisted of combining these sub-assemblies and components. Crucially, CBP found that the Vietnamese processing of non-originating parts and components into sub-assemblies, and the final assembly of these sub-assemblies with any additional non-originating parts and components, resulted in the substantial transformation of those parts and components into finished vacuum cleaners of Vietnamese-origin. 7 Both manufacturing scenarios of the Model AC4825 are similar to the first manufacturing scenario discussed within HQ H303177. In both manufacturing scenarios, various Chinese- origin electrical and non-electrical components are imported to Vietnam where they are combined with Vietnamese-origin injection-molded plastic components and other parts where they are processed into sub-assemblies and ultimately assembled into finished air purifiers. The sole difference between the manufacturing scenarios detailed within NY N322364 is that, whereas the motor is of Vietnamese-origin in the first manufacturing scenario, it is of Chinese- origin in the second manufacturing scenario. Despite this, in either manufacturing scenario the air purifier is constructed from Vietnamese-origin injection-molded plastic components and assembled in Vietnam. As demonstrated, the “character of the finished air purifier differs from that of the imported materials,” because these Chinese-origin components “lose their individual identities and become an integral part of a new article when assembled,” with Vietnamese components. One such component is the Chinese-origin motor. Prior to its arrival in Vietnam, the Chinese-origin motor has the capability to convert electrical energy into mechanical energy. It is only after the Chinese-origin motor is assembled with electrical components and fan blades in Vietnam that it becomes a motor assembly. While this motor assembly can generate airflow, it can neither filter nor purify air until it is combined with the other, Vietnamese-made sub- assemblies to create the finished air purifier. In doing so, each of the foreign components, including but not limited to the Chinese-origin motor, loses its individual identity and becomes an integral part of the finished air purifier. This understanding is also consistent with the holdings of NY N324519, NY N322606, NY N322549, and NY N319176, in which Chinese and Vietnamese-origin parts and components underwent manufacture in Vietnam into sub-assemblies and final processing into finished vacuum cleaners of Vietnamese-origin as a result of their substantial transformation. These components included a Chinese-origin motor assembly, capable of converting electrical energy into mechanical energy prior to importation into Vietnam. However, it was not until this Chinese-origin motor assembly was combined with other, functionally crucial sub-assemblies – the dust cap assembly, the nozzle assembly, and the body assembly – that the product could act as a finished vacuum cleaner. As such, each of the foreign components, including but not limited to the Chinese-origin motor assembly, loses its individual identity when manufactured and processed into finished vacuum cleaners. Therefore, we find that the country of origin of the Model AC4825 is Vietnam regardless of its enumerated manufacturing scenario. NY N322681 (GermGuardian AC4300BPTCA Elite 5-in-1 Air Purifier) NY N322681 discussed two manufacturing scenarios for the Model AC4300. In the first manufacturing scenario, the UV lamp, UV lamp holder and protection board, UV lamp box, UV lamp cover, UV lamp ring sub-assembly, PCB assembly, fan switch, motor switch assembly, HEPA filter, air outlet iron net, and power cord were imported from China. The remaining components and parts, including the injection-molded housing components, fan, motor frame, control panel, PCB box, brackets and switches, screws and fasteners, microswitch boxes, and packaging components, are all manufactured in Vietnam. The second manufacturing scenario is similar to the first manufacturing scenario, except 8 that additional components, such as the top and bottom fan housing, fan, switch boxes, frames, control panel, brackets, and switches, are sourced from China. The remaining components and parts – including the injection-molded plastic parts, screws, and various packing/labelling materials – are manufactured in Vietnam. In NY N322681, CBP found that the country of origin of the Model AC4300 was China under both manufacturing scenarios. Specifically, CBP found that “the finished device consists of several important subassemblies such as the motor, fan, UV lamp and PCB (with embedded Chinese software), which are previously manufactured in China,” and that these “most expensive items […] impart[] the critical functionality for the air purifier.” CBP elaborated that “these items do not lose their core abilities when assembled in Vietnam” because “the assembly operations performed in Vietnam, which consist of attaching, fastening, straightening wires, and gluing, is not complex.” Therefore, CBP found that the assembly operations performed in Vietnam were not enough to substantially transform the non-originating parts and components into products of Vietnamese origin, instead finding that the Model AC4300 was a product of China under both manufacturing scenarios. Based on the information presented, we find that the Model AC4300 is a product of Vietnam regardless of its manufacturing scenario. In both manufacturing scenarios, parts and components utilized in the production of the finished Model AC4300 are of either Chinese or Vietnamese-origin. Regardless of the manufacturing scenario, the UV lamp, UV lamp holder and protection board, UV lamp box, UV lamp cover, UV lamp ring sub-assembly, PCB assembly, fan switch, motor switch assembly, HEPA filter, air outlet iron net, and power cord are imported from China, while the injection-molded plastic parts, screws, and various packing/labeling materials are of Vietnamese-origin. In the first manufacturing scenario, the top and bottom fan housing, fan, switch boxes, frames, control panel, brackets, and switches are of Vietnamese-origin, whereas they are sourced from China in the second manufacturing scenario. These components are combined with each other in Vietnam to install or produce various sub- assemblies, such as the control panel, UV lamp assembly, decorative lamp strip, various wire/terminal preparation, rotary switch assembly, UV protective board processing, microswitch PCBA installation, motor assembly installation, and the rear shell/housing assembly. The sub- assemblies and component parts are then utilized to manufacture the finished Model AC4300. This manufacturing process consists of inspecting the plastic molded front housing, installing the iron outlet to the front housing, shaping and affixing iron outlet locking foot in the machine, installing the motor compartment, affixing the motor bracket to the front housing, affixing the air duct to the front housing, connecting the top control panel, installing UV lamp components, installing the PCB box, installing the PCB fireproof box, installing the top housing, installing the top cover, affixing the UV lamp to the front housing, connecting the front and rear housing wires, assembling the front housing and rear housing and installing the UV, securing the top cover and UV lamp protection board, and affixing the filter to the rear housing. Consequently, in this case, based on the information presented, we believe that the production of the air purifiers in Vietnam in both manufacturing scenarios is more than a simple assembly operation and distinguishable from other devices containing an electric motor because it involves complex and costly processing operations, which encompasses a significant number of individual components 9 Given that the Model AC4300 is fundamentally identical to the Model AC4825, both in its processes of manufacture and in its identity, we find the aforementioned country of origin analysis pertaining to the Model AC4825 to be informative in our country of origin analysis of the Model AC4300. As such, we again turn to the analyses detailed within HQ H303177, NY N324519, NY N322606, NY N322549, and NY N319176 to determine the country of origin of the Model AC4300. The Model AC4300, like the Model AC4825, begins its manufacture with the importation of Chinese-origin components to Vietnam. These Chinese-origin components are combined with Vietnamese-origin components, including injection-molded plastic components, to form various sub-assemblies. These Vietnamese-manufactured sub-assemblies are assembled with components of either Chinese of Vietnamese-origin to construct the final air purifier. As in our analysis above, pertaining to the Model AC4825 air purifier, we find that the assembly operations in Vietnam under the first and second manufacturing scenarios of the Model AC4300 – which include the injection-molding of plastic components, the production of sub- assemblies from Chinese and Vietnamese-origin components, and the assembly of these sub- assemblies into the finished air purifiers – as sufficiently complex and meaningful as to substantially transform the non-originating components. The Vietnamese operations are strongly similar to those discussed within HQ H303177 – where the injection molding of plastic components and the ultimate assembly occurred in the same country – as well as NY N324519, NY N322606, NY N322549, and NY N319176 – where non-originating components and parts, including a Chinese-origin motor assembly, were combined with other components and parts to form distinct sub-assemblies, which were then ultimately assembled in the country of origin. These plastic components formed “an integral part of the finished device’s character and use because they form the structure and appearance of the device.” Without these plastic components, the finished air purifier would neither be identifiable nor usable for its intended purpose. Although important Chinese-origin components serve to render the air purifier operable, these components lose their individual identities and become an integral part of the new article of commerce – the finished air purifier – when assembled with Vietnamese components in Vietnam. One such example is that of the Chinese-origin motor. Prior to its importation into Vietnam and its combination with other parts to form the motor sub-assembly, the Chinese-origin motor can convert electrical energy into mechanical energy, but is incapable of moving, filtering, or purifying air. It is only after the manufacture of the motor sub-assembly, and its subsequent combination with other sub-assemblies, that the finished air purifier possesses the capability of moving, filtering, and purifying air. As such, the components which serve to render the air purifier operable lose their individual identities and become integral parts of the finished air purifier. Therefore, the country of origin of the Model AC4300 is Vietnam regardless of its enumerated manufacturing scenario. HOLDING: Based on the facts provided, the country of origin marking of the Model AC4825 is Vietnam. 10 Based on the facts provided, the country of origin marking of the Model AC4300 is Vietnam. EFFECT ON OTHER RULINGS: NY N322364, dated November 18, 2021, is hereby MODIFIED. NY N322681, dated December 1, 2021, is hereby REVOKED. In accordance with 19 U.S.C. § 1625(c), this ruling will become effective 60 days after its publication in the Customs Bulletin. Sincerely, Yuliya A. Gulis, Director Commercial and Trade Facilitation Division 11