The country of origin of an oil filter

N350345 July 8, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Anchalika Prachakool QAP Filter (Thailand) Co., Ltd. 98/3 Moo 11, Nongbua subdistrict, Bankhai district Rayong 21120 Thailand RE: The country of origin of an oil filter Dear Ms. Prachakool: In your letter dated June 18, 2025, you requested a country of origin ruling on an oil filter. Descriptive literature was provided for our review. The item under consideration is described as an oil filter, which is a key component of an engine lubrication system designed to remove contaminants from engine oil, preventing damage to the engine. The filter traps particles like dirt, metal shavings, and carbon deposits, ensuring that clean oil circulates and lubricates the engine’s moving parts. To install the filter, the user would apply oil on the outer sealing ring of the product and then place the inner thread against the outer thread of the filter seat. The user would then rotate the product until the top surface of the outer sealing ring contacts the base surface of the filter seat. The oil filters are assembled in Thailand using components from Thailand and China. The Thai components include the spray shell assembly, shell, hot dip galvanized sheet, black powder, oil filter element assembly, central tube, origami (pleating or folding of the filter paper to increase its surface area for more efficient filtration), screw fit plate assembly, threaded cover plate, and some of the packaging including corner protectors, tray cover, pallet, and outer box. The Chinese components include the upper-end cover, adhesive, galvanized thin sheet, filter paper, lower end cover assembly, diaphragm, silicone rubber, sealing plate, toothless cover plate, sealing ring, and some of the packing including the color box, labels and dust film. The assembly process occurs in Thailand and includes thirty-four individual steps. The process starts with shell punching using a punch press. Then, a 6-axis tapping machine is used to punch holes into the metal followed by oil being sprayed onto the metal. After the thread inspection, the cover plate is cleaned, the sealing plate is injected with glue, and the screw-fit plate is spot welded. The eighth step includes the center tube manufacturing followed by the shell cleaning, powder coating the metal parts, and screen printing. Next, the origami is made on a reciprocating origami machine with the resulting strips clipped together using a strip clamping machine. Then, the end cap is glued on, the center tube is placed, and the upper and lower end covers are assembled before heading to the baking tunnel (oven). The screw board is then injected with glue and the check valve is installed before the filter element is assembled and the release spring is added. The next step involves adding the outside housing and seal before wiping and inspecting the product. Finally, the product is laser marked, sprayed with anti-rust, the sealing rings are assembled, final threading inspection is conducted, and packaged. 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 oil filter, it is our opinion that the manufacturing and assembly process performed in Thailand is considered complex. Numerous steps are needed to transform the individual components from China into a finished oil filter in Thailand. The individual components each have a change in name, character, and use. Therefore, in our opinion, the country of origin of the oil filter is Thailand, which is where the assembly process occurs, half the components are manufactured, and the Chinese components are transformed into a finished oil filter. 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) James Forkan Acting Director National Commodity Specialist Division