The country of origin of a diesel fuel filter

N350865 July 22, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Anchalika Prachakool QAP Filter (Thailand) Co., Ltd. 350/40 Moo 6, Nongbua subdistrict, Bankhai district Rayong 21120 Thailand RE: The country of origin of a diesel fuel filter Dear Ms. Prachakool: In your letter dated July 2, 2025, you requested a country of origin ruling on a diesel fuel filter. Descriptive literature was provided for our review. The item under consideration is described as a diesel fuel filter, which is a component of a diesel engine’s fuel system. It is designed to remove contaminants like dirt, water, and other debris from the diesel fuel before it reaches the engine’s sensitive components, such as fuel injectors. This helps to protect the engine and ensure optimal performance. To install the filter, the user would first remove the old filter using a strap wrench or by unscrewing it by hand. Then they would clean the housing and replace and lubricate the O-ring before installing the new filter. The user would position the new filter, tighten it by screwing it in, and reconnect any fuel lines. Finally, the user would prime the fuel system according to the vehicle’s manual to remove any air. The diesel fuel filters are assembled in Thailand using components from Thailand and China. The Thai components include the filter element assembly, filter paper assembly, origami (pleating or folding of the filter paper to increase its surface area for more efficient filtration), and some of the packaging that includes corner protectors, a cover plate, a pallet, and an outer box. The Chinese components include the upper-end cover, lower-end cover, filter paper, tinplate, glue, center tube, wire mesh assembly, sealing ring, O-ring, handle, and some of the packing that includes the instructions, paper box, and labels. The assembly process occurs in Thailand and includes fifteen individual steps. The process starts with the origami, which is made on a reciprocating origami machine. Next, the paper is slit and broken so that it can be rolled onto the center tube. This is followed by adding clamping strips using an automatic clamping machine. Then, the lower cover is filled with glue before being fitted with the paper core. Once complete, the product is sent to the oven for curing. After curing, the upper-end cover is injected with glue and fitted with the paper core before going back to the oven for additional curing. Finally, the product has the code sprayed, laser marked, and then 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 diesel fuel 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 diesel fuel 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 diesel fuel filter is Thailand, which is where the assembly process occurs, half the components are manufactured, and the Chinese components are transformed into a finished diesel fuel 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