The country of origin of heat pump units

N348913 May 29, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Julia Schilling Eberspacher Gruppe GmbH & Co. KG Eberspacherstr. 24 Esslingen am Necker 73730 Germany RE: The country of origin of heat pump units Dear Ms. Schilling: In your letter dated May 12, 2025, you requested a country of origin ruling on heat pump units. Descriptive information was provided in the submission. The products at issue are heat pump units, part numbers 29.0218.41.0001 and 29.0218.41.0002. The rooftop heat pump units are referred to as air-conditioning units and are intended to be installed on the roof of recreational vehicles, caravans, pop-top caravans and camper trailers. The units, which are powered using an alternating current power supply, are designed to change the temperature and humidity levels within a vehicle while stationary. The heat pumps consist of a shroud cover and a bottom plate assembly that enclose a compressor, an evaporator, a condenser, and other components that contribute to the cooling process. With respect to origin, you describe three origin scenarios for the heat pump units. For scenarios one and two, the final assembly occurs in China, and for scenario three, the final assembly occurs in India. Prior to the final assembly, the compressor is assembled in India in scenario one and is assembled in China for scenarios two and three. The assembly of the compressor begins by casting the housing from aluminum or iron material, which is followed by the fabrication and machining of a crankshaft, a cylinder head and a piston. These components, along with various other components, are used to construct subassemblies, such as a rotor and stator subassembly, a piston and cylinder subassembly and a motor-driven subassembly for electric compressors. Throughout these steps, lubrication is applied, and seals and valves are installed in the compressor housing. Afterwards, the compressor undergoes testing and a final inspection. Once the inspection is complete, the compressor undergoes a coating and is marked with a laser. In the three scenarios, the evaporator and condenser are assembled in India prior to the final assembly. For the evaporator, tubes are cut to length using automatic tube cutters and subsequently bent into shape. Next, aluminum sheets are stamped into fins using die stamping machines. The tubes are then expanded inside the fin stack. Afterwards, tubes and fins are assembled into a core using automated assembly lines or by manual stacking and then placed in a furnace to be heated to temperatures of approximately 600–700 degrees Celsius. Once the brazing process is complete, the remaining residues are removed using chemical cleaning, and the evaporator is subject to inspections and various testing. After the inspections and testing are completed, the end connections and headers are installed, and the tube ends are flared and connected to the headers. Lastly, anti-corrosion coatings are applied. For the condenser, aluminum sheets are cut into sections, and the sectioned sheets are stamped using stamping machines to form thin, corrugated fins. Subsequently, copper tubes are cut and trimmed into the required lengths. The tubes are then bent using tube benders, and the tubes and fins are assembled into the core of the coil. Once the brazing process is complete, the header is attached to the tube assembly and the end plates are welded in place. The completed condenser undergoes inspections, testing, and is afterwards coated with protective layers to prevent corrosion. Lastly, mounting brackets are installed. The final assembly of the heat pump units begins by installing a Chinese compressor base plate, attaching a sponge to a base pan, and installing a foam onto the evaporator. Next, a rubber cover washer, a power cord, and a cover are installed onto the compressor and the process continues by appropriately connecting the ground wire. The compressor is then mounted into the unit and secured in place using screws. Afterwards, two blowers from China are connected; one blower is connected to an evaporator and another to the condenser. The necessary pipe connections are assembled and welded to the evaporator and condenser. The required brazing is completed, and the condenser’s housing and sponge are installed. Wiring is then routed, and a Chinese sourced control box is installed and connected. Throughout these steps, inspections and testing are completed. Lastly, a Chinese sourced shroud is installed, and the finished heat pump unit is labeled and packaged. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, 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). Based on the manufacturing scenarios presented in the submission, the final assembly operations, which occur in either China or India, do not result in a substantial transformation. The components are installed using processes that are rather simple. As such, we look to the origin of the cooling components, which consist of the evaporator, condenser and compressor, as the function of air conditioning units is to change the temperature and humidity levels within a space. In scenario one, the cooling components are from India. Accordingly, the country of origin of the heat pumps for scenario one is India. However, in the scenarios two and three, it is noted that the cooling components do not originate from the same country. In these instances, CBP has determined that the origin of air conditioning units is determined by the majority of the cooling components. See Headquarters Ruling Letters H320036 and H320039, both dated November 18, 2001, and H319823, dated November 18, 2001. Therefore, as the majority of the cooling components described in the scenarios two and three are from India, the country of origin of the heat pump units for scenarios two and three is India. 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 Sandra Martinez at sandra.martinez@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division