The country of origin of electric water filter dispensers

N348298 May 21, 2025 OT:RR:NC:N4:410 CATEGORY: Country of Origin Chris Wang Qingdao Ecopure Filter Co., Ltd. No.13, Yishengbai Road, Jimo, Qingdao Qingdao 266201 China RE: The country of origin of electric water filter dispensers Dear Mr. Wang: In your letter dated April 27, 2025, you requested a country of origin ruling on the electric water filter dispensers. The merchandise under consideration is referred to as electric water filter dispensers. It is stated that the product models include but are not limited to WD-ED01W, WD-ED01B, WD-ED01LB, WD-ED01P, WD-EDC01W, WDEDC01B, WD-ED01AB, WD-ED01AW, BW-WD-ED10G, WD-ED61W, WD-ED61B, WDED02W, WD-ED02B, WD-ED04W-L and WD-ED04B-L. The electric water filter dispensers are almost the same in structure and the filters used for these machines are different in size, i.e., the WD-ED01 series and WD-ED61 series are for the 15-cup, WD-ED02 series is for 14-cup, and WD-ED04 series is for 27-cup models. The electric water filter dispensers each are comprised of a transparent water tank, a water pumping unit and a tank lid. The water pumping unit contains a circuit board, a battery and a water purification filter element. The transparent water tank can be filled with tap water. The user can control the water by controlling the touch screen panel of the water applicator, and the water is then passed through the filter to remove dissolved solids and other impurities, and the clean water is always available. The electric water filter dispensers do not incorporate a heating or refrigerating device (function). They are designed solely for water filtration purposes and do not alter the temperature of the water. The products use components manufactured in the Republic of South Korea and China. The key component of the filter, the carbon block, is purchased from South Korea, while other components are finished parts purchased from various suppliers in China. 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 filter rods are made in South Korea from carbon blocks and non-woven fabric. The carbon blocks are produced with carbon powder, binder, etc., by mixing these raw materials evenly under certain conditions, in which the powdered mixture is pressed into molds using a canning machine under pressure in the molding process. The molded carbon blocks are pre-baked in an oven at high temperature, and then compression at high temperature in a furnace. During the compression process, the carbon blocks are heated to the point where the particles begin to bond together, resulting in a denser and more durable product. After the compression, the carbon blocks are cut and polished to their final dimensions and wrapped with non-woven fabric. The carbon rods are then shipped to China to combined with the Chinese-made parts and components, e.g., the sump assembly, water pumping unit and the tank and kit, to construct the finished electric water filter dispensers. The sump assembly consists of a plastic middle cover, sump, cover, bottom cover and rubber O-rings. The water pumping unit consists of a plastic adapter, top cover, housing, water nuzzle, touch screen, solenoid valve, main control panel, diaphragm pump, silicone tube, PE tube, plug, battery and screws. The tank and kit consist of a clear plastic water tank, tank lid, sponge brush, Type-C power cable and foot pads. In the Chinese factories, the plastic parts and components are made from the extrusion or plastic molding process. The solenoid valves are made by assembling the plastic casing, magnetic conductive plate, magnetic conductor, iron core, etc., into finished products according to the structural design. The diaphragm pumps are made by bonding and assembling components such as plastic casings, motors, and terminal leads into finished water pumps. The main control panels are fabricated via the SMT (surface mount technology) process, in which the PCBAs (printed circuit board assemblies) are produced by populating or bonding the components such as chip capacitors, LED lamps, chip resistors, single-chip microcomputers, and flexible flat cables into the PCBs for the fabrication of main control panels. 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). In regard to the country of origin of the electric water filter dispensers, we find that, except for the filter rods which are made in South Korea, all other parts or components, which substantial in number and account for the majority of production costs, are made in China. The manufacturing operations including the SMT process, rubber extrusion and plastic injection, along with other assembly activities in China, are complex and meaningful. Noting the filter rods are important components in the subject filter dispenser, the manufacturing process in China does create a new and different article of commerce with a distinct character and use that is not inherent in the components imported into China. Therefore, the country of origin of the electric water filter dispensers is China for purposes of current trade remedies. 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 Michael Chen at michael.w.chen@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division