The country of origin of a filter press

N340517 June 24, 2024 OT:RR:NC:N1:105 CATEGORY: Origin Hyun woo HanLG Chem128, Yeoui-daero, Yeongdeungpo-guSeoul, South Korea 07336 RE:  The country of origin of a filter press Dear Mr. Han: In your letter dated June 4, 2024, on behalf of your client, TSE Company Limited, you requested a country of origin ruling on a filter press. The item under consideration is described as a filter press, which is a high-efficiency solid-liquid separation device. The equipment is a fully automatic device that realizes solid-liquid separation by quickly filtering the slurry through a filter cloth using the pressure of a pump, the weight of the material, and the compression action of the diaphragm. It is widely used in metallurgy, mining, chemical, coal chemical, titanium dioxide, paper, food, pharmaceutical, environmental production, and many other industries as an alternative to conventional filtration and pressure filtration equipment. The basic operating sequence includes the water supply, followed by compression, cleaning, another compression, drying, and finally draining. The water supply slurry that is to be separated is transferred through a pump to a filter plate, and the solid and liquid in the slurry are transferred separately. The slurry properties, including the mixing ratio of solid and liquid are applied according to the amount of livery. In the compression phase, the slurry is separated in the liquid supply stage and the solid (cake) remaining on the top of the filter cloth is subjected to hydraulic or pneumatic pressure. The step is designed to expand the diaphragm on the top of the filter plate to remove residual liquid in the cake. The next step is the cleaning process, which removes certain remaining components in the cake formed in the pressing process with liquid. This compression step uses water pressure or pneumatic pressure to apply residual liquid in the cake used in the washing process to the top of the filter plate. In this process, the remaining liquid in the cake is filtered through the filter cloth. The drying (blazing) allows compressed gas to pass through a solid from which liquid has been removed at a certain level in the compression stage. The solid is cake or powder depending on the characteristics of the object to be separated. The last step is draining, which transfers the solid from which the liquid is separated to the desired level. Regarding the origin of the filter press, in Korea, the manufacturing process starts with obtaining all of the materials. The main raw materials and origin used in the manufacture of the filter press include the main frame, control panel, and pressed water tank that are from South Korea. The hydraulic cylinder, filter cloth, and filtration gun drive device are all manufactured in China. Roughly 100 types and 3,000 parts are used to manufacture the filter press. The products are classified into raw materials, purchased products, and manufactured products. Raw materials are required to manufacture machinery (steel plates, pipes, steel, plastic, etc.). Purchased products are off-the-shelf products that can function alone (all electrical equipment for pumps, valves, sensors, panels, etc.). Production includes raw parts or semi-finished products (filter press cylinder base, washing container, tension frame, filter plate frame, pressed water tank, etc.). The next step includes producing the articles needed according to the design specifications. Production articles are divided into self-made and outsourced items. Parts that require understanding of vertical filter presses are self-made parts that are possible with general technology (tanks, workstations, etc.) or parts that require specific technology (electric control panel, hydraulic station) are outsourced. In-house manufactured products are ordered by purchasing raw materials and subjecting them to laser or other mechanical processing to perform processing inspection and pipe welding within the company's workplace. Parts and semifinished products that have been manufactured during the first stage undergo a surface treatment process after intermediate inspection. In the case of stainless steel, buffing or pickling, electrolytic polishing, and carbon steel are treated with powder coating after short circuit. Outsourcing products are manufactured by combining finished products due to the characteristics of the electric control panel. After receiving the articles that have been manufactured, an inspection is conducted, visual, dimensional check, contamination level, etc. The products that do not meet the standards are reprocessed or remade. The assembly process starts with the assembly of the roller, bearing base, roller, and hydraulic motor base of the washing container in order. Each roller has a different shape depending on the role. The main body is assembled in the order of cylinder base, cylinder, lower plate, filter plate, and finally, upper plate. The lower plate, which is assembled on top of the cylinder, is a heavy weight, so it must be assembled by a person skilled in handling heavy goods. Since the filter plate has different shapes, depending on each plate, the person skilled in installing each plate separately must perform the assembly. The tension frame is assembled in the order of the sprocket, roller, and filter cloth eccentricity control device. The manufacturer will connect the finished part assembly to the main body. After assembling the main body and the cleaning container, assembly of the tension frame on the top of the cleaning container is completed. At this time, each part is assembled. Next, for the equipment that has been assembled, the filter cloth is tested with a test panel and a hydraulic station prior to installation. This is followed by various checks and tests then the packaging and delivery. The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. 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 U.S. the English name of the country of origin of the article. The “country of origin” is defined in 19 CFR 134.1(b) 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 this part.” 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, 69 C.C.P.A. 151 (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).Regarding the country of origin of the filter press, in our view, the manufacturing process performed in Korea would be considered complex. Over 3000 components and subassemblies are gathered from numerous countries (including Korea, China, Japan, Germany, Indonesia, France, Italy, and the United States) and combined in order to generate a functional filter press. Each of the individual components lose their identity during the manufacturing process. Therefore, the manufacturing and assembly process creates a new name, character, and use different from the individual components. Accordingly, for origin and marking purposes, the filter press would be considered a product of Korea at the time of importation into the United States. 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 jason.m.christie@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division