The country of origin of an exhaust manifold catalytic converter assembly

N350063 June 27, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Jae Yeoung Cha SEIN Customs & Auditing Corp 138, Seoun-ro, Seocho-gu Seoul, South Korea 06619 RE: The country of origin of an exhaust manifold catalytic converter assembly Dear Mr. Cha: In your letter dated June 11, 2025, on behalf of your client, Hyundai Motor Company, you requested a country of origin ruling on an exhaust manifold catalytic converter assembly. Descriptive literature was provided for our review. The item under consideration is described as an exhaust manifold catalytic converter assembly (part number 285102GAV0), which is mounted on the cylinder head of an automobile engine. The device performs the function of cooling and expanding the high-temperature, high-pressure exhaust gases generated by automobiles into a low-temperature, low-pressure state, thereby purifying the exhaust gases and directing the gas flow safely. The item is designed to be directly bolted to the cylinder head of an automobile engine. The exhaust manifold catalyst assembly measures 327 mm wide by 300.34 mm long by 256.14 mm high and weighs 6.37 kg. The exhaust manifold catalyst assembly is made from seven core components. The Korean components include the manifold assembly (guides high-temperature exhaust gases generated from the engine cylinder toward the catalyst); the shell (wraps and secures the internal catalyst and the supporter, and guides exhaust gases to flow through the correct path); the upper cover and the lower covers (protect surrounding components from heat, also securing the shell, the internal catalyst, and the supporter); the supporter (located around the catalyst, it absorbs shocks and secures its position, while also blocking heat transfer to the outside); and the RR cone sub (maintains airtightness at the connection point with the rear muffler to prevent exhaust gas leaks). The catalyst, which is manufactured in the United States, performs the role of purifying Carbon Monoxide (CO), Hydrocarbons (HC), and Nitrogen Oxides (NOx) in exhaust gases through oxidation and reduction reactions. The U.S. made catalyst makes up 77.3% of the overall material cost of the exhaust manifold catalytic converter assembly. The manufacturing process begins in the United States with the production of the catalyst through a ten-step process. First, precisely measured refined clay, alumina, and other ceramic powder raw materials are mixed with water, dispersants, etc., to produce a uniform dough. Then the dough is put into an extruder to form the honeycomb cell structure of the substrate. The extruded long honeycomb-shaped substrate is then cut into uniform lengths. The cut substrate undergoes moisture removal in a drying machine before being placed into a high-temperature kiln to bind the ceramic particles together, forming a porous honeycomb structure. Next, the precious metals (Platinum, Palladium, Rhodium) used as active components of the catalyst, are received in powder form and reacted in a special solvent to dissolve it and produce a uniform precious metal solution. In the next step, a uniform washcoat slurry is prepared by mixing high-surface-area oxide powder with purified water and additives. A catalyst slurry is prepared by mixing the precious metal solution with the washcoat in slurry form. The prepared catalyst slurry is sprayed onto the ceramic substrate, evenly coating the microscopic channels inside the substrate, and then dried. After heat treatment in a high-temperature kiln, the completed catalyst is exported to South Korea. The remaining nine steps are all completed in South Korea. The U.S.-made catalyst is imported, inspected for specifications and appearance, then received. Stainless steel coil is loaded onto blanking line equipment, continuously drawn out into sheet metal form, then cut to specification. Afterwards, individual component parts are formed through a press process. This is followed by canning, which is a method of precisely inserting the catalyst, after wrapping its exterior with a supporter, into the shell. Then, the main stainless-steel components are loaded onto a weld jig, secured, and welded into the finished article. The welded product is then placed onto a leak tester, and the airtightness and integrity of the welds and assembly are checked using air pressure. Finally, the finished article is labeled, packaged and shipped to the United States. 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). Based on the facts presented, we find that the assembly operations performed in South Korea, which consist of the wrapping of the catalyst with a supporter, canning, and welding the stainless-steel components into place, do not constitute a substantial transformation. The U.S.-origin catalysts are not substantially transformed during the operations performed in South Korea because the primary function of the catalyst is left intact. The additional stainless-steel components only act to protect the catalyst and direct the flow of the emitted gas. Accordingly, we find that the catalyst imparts the essence of the completed exhaust manifold catalytic converter assembly (part number 285102GAV0) and, hence, the origin of the completed exhaust manifold catalytic converter assembly is 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, (for) Steven A. Mack Director National Commodity Specialist Division