The country of origin of a water filter tank and replacement water filters

N347698 May 2, 2025 OT:RR:NC:N1:105 CATEGORY: Country of Origin Chris Wang Qingdao Ecopure Filter Co., Ltd. No.13, Yishengbai Road, Jimo Qingdao 266201 China RE: The country of origin of a water filter tank and replacement water filters Dear Mr. Wang: In your letter dated April 11, 2025, you requested a country of origin ruling on a water filter tank and replacement water filters. Descriptive literature was provided for our review. The first items under consideration are described as water filter tanks (model numbers ECF-7088 and ECF-7090). The products are made of a Chinese upper chamber, lower chamber, lid and spigot. They are also shipped with a South Korean filter element. When using the products, the user first pours water into the upper water chamber. The water then flows through the filter element and into the lower chamber. The user can then open the spigot on the bottom of the lower chamber to obtain filtered drinking water. Each model is identical other than the ECF-7090 has a 1.5 gallon capacity and the ECF-7088 has a 2.25 gallon capacity. Additionally, the ECF-7088 is shipped with a stand containing a non-slip mat, spigot, washing gasket and wrench, while the ECF-7090 is shipped with just the spigot and washing gasket. The second item under consideration is described as the EWF-8090 replacement water filter, which is specifically designed for use with the two water filter tanks. The EWF-8090 will be packaged with the ECF-7088 and ECF-7090 products as well as shipped separately as a replacement filter. The filter is assembled in China using components manufactured in South Korea and China. The filter element is made of a Chinese O-ring, upper cover, middle cover, bottom cover, and a South Korean carbon block. The carbon block removes contaminants from water through a process called “adsorption.” Adsorption is a process in which contaminants are attracted to the surface of the carbon granules and become trapped in the small pores of the filtration media. The carbon block requires substantial processing to create and accounts for the largest cost of the overall filters. The entire production and packaging process includes six steps and is completed by seven workers. It is divided into two parts: filter element assembly and tank assembly and packaging. The filter element assembly consists of three steps and is completed by four workers. The first step in the filter assembly process involves one worker manually inserting the O-ring into the top cover. During this step, visual inspection is conducted to ensure there are no scratches, stains, or color differences. The next step involves one worker operating glue dispensing equipment to glue the middle cover, carbon rod, and bottom cover together. During this step, the carbon block is pressed vertically without damaging it and it is evenly bonded. The third step involves one worker operating a rotary welding machine to weld and bond the upper cover, glue-dipping carbon rod, and sump to form a complete filter element. Finally, a self-inspection is performed to check that the product is free from stains, overflowing glue, cracking, etc. This is followed by boxing and packing for shipment. For the tank assembly, one worker puts expanded polyethylene (EPE) foam into the lower chamber, followed by placing the filter element and accessories on the EPE. Another worker then checks that there is no leakage before placing the upper chamber upside down on the lower chamber and finally put the lid on it. This is followed by boxing and sealing the assembled tank for final shipping. When determining the country of origin, 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). Regarding the country of origin of the water filter tanks (model numbers ECF-7088 and ECF-7090), it is our opinion that the assembly process performed in China is not complex and does not constitute a substantial transformation. The process predominantly involves bending and cutting the stainless-steel, and gluing, welding, and pressing various components into place. The combining of these parts in China does not create a new and different article of commerce with a name, character, and use distinct from the individual components. Therefore, to determine the country of origin of the water filter tanks, we rely on the origin of the carbon block, which provides the essential function of the tanks. It is the carbon block from South Korea which requires considerable technical expertise and customized equipment to produce. It is also the item performing the filtering of the water. Accordingly, the country of origin of the water filter tanks (model numbers ECF-7088 and ECF-7090) will be South Korea, which is where the carbon block is manufactured. Regarding the country of origin of the replacement water filter when imported separately from the tank, it is our opinion that the assembly process performed in China is not complex and does not constitute a substantial transformation. The process predominantly involves gluing, welding, and pressing various components into place. The combining of these parts in China does not create a new and different article of commerce with a name, character, and use distinct from the individual components. Therefore, to determine the country of origin of the replacement water filter, we rely on the origin of the carbon block, which provides the essential function of the filter. It is the carbon block from South Korea which requires considerable technical expertise and customized equipment to produce. It is also the most expensive portion of the filter and is the item performing the filtering of the water. Accordingly, the country of origin of the EWF-8090 replacement water filter will be South Korea, which is where the carbon block is manufactured. 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