The country of origin of a replacement water filter

N350079 June 25, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Jamie Smith Access Business Group International LLC 7575 Fulton Street East Ada, MI 49355 RE: The country of origin of a replacement water filter Dear Mr. Smith: In your letter dated June 11, 2025, you requested a country of origin ruling on a replacement water filter. Descriptive literature was provided for our review. The item under consideration is described as the eSpring e3 Carbon Filter for the eSpring Water Treatment System. The filter uses a three-layer filtration system to filter and purify water. It first removes larger particles like sediment and scale precipitate through a pre-filter. Then, a “Defense Guard” layer captures fine particles like microplastics and asbestos. Finally, a carbon block effectively reduces a wide range of contaminants, including pharmaceuticals, lead, mercury, pesticides, herbicides, and volatile organic compounds (VOCs) down to 0.2 microns. This layered approach, combined with UV-C LED technology that destroys bacteria and viruses, ensures clean and healthy water. The eSpring e3 Carbon Filter is assembled in China using components manufactured in the United States and China. The filter is comprised of a United States origin carbon block, and Chinese origin adhesive, pre-filter, outer wrap, top endcap and bottom endcap. The carbon block is the most expensive portion of the filter and also performs the primary filtering function for the system. 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 assembly process in China starts with gluing and attaching the outer wrap to the exterior of the carbon block. Then, a worker applies the o-ring to the top end cap. This is followed by applying glue to both the top cap and bottom cap and attaching them to the carbon block. Next, the pre-filter is inserted over the filter assembly before shrink-wrapping the filter. Finally, the filter is tested, labeled, and packaged for final shipment 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). Regarding the origin of the eSpring e3 Carbon Filter, the assembly process predominantly involves screwing, gluing 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 the United States which requires considerable technical experience and customized equipment to produce. It is also the most expensive portion of the filter, and it is the item performing the filtering of the water. Accordingly, the country of origin of the eSpring e3 Carbon Filter will be the United States, 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, (for) Steven A. Mack Director National Commodity Specialist Division