COUNTRY OF ORIGIN AND MARKING OF IMPORTED WATER DISPENSERS

N048415 February 6, 2009 MAR-2 OT:RR:NC:1:102 CATEGORY: MARKING Mr. Rotem Virnik Gill Nadel Law Offices 10 Hamelacha Street Lod, Israel 71520 RE: COUNTRY OF ORIGIN AND MARKING OF IMPORTED WATER DISPENSERS Dear Mr. Virnik: This is in response to your letter dated December 21, 2008 requesting a ruling on the country of origin of water dispensers manufactured by your client Tana Water. Information describing the articles in question and their manufacture was submitted. You indicate that the dispensers, which are designed for direct connection to a water supply and are self-programmable to enable water to be filtered and dispensed at any desired water temperature, are manufactured in Israel from a number of components. The main components include a compressor, condenser, heating system, hot and cool water tanks, a filtering system, control unit, display panel and software. The components are sourced mainly from the United States, China, Korea, Italy and Israel. In addition to research, design, engineering and product development, the manufacturing operations performed in Israel, include cutting pipes and wires to size, welding components together, installing software, testing and packaging.  Part 134, Customs Regulations (19 CFR Part 134), implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b) of the Customs Regulations 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." While certain components that go into the manufacture of the dispensers are made in countries other than Israel, based on the information you have provided, we find that the components undergo a substantial transformation when subjected to the manufacturing operations performed in Israel. Therefore the country of origin of the subject water dispensers is Israel and “Made in Israel” is an acceptable country of origin marking for dispensers imported into the United States. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 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, contact National Import Specialist Kenneth Brock at (646) 733-3009. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division