The country of origin of an automotive air conditioning filter

N351082 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 an automotive air conditioning filter Dear Ms. Prachakool: In your letter dated July 8, 2025, you requested a country of origin ruling on an automotive air conditioning filter. Descriptive literature was provided for our review. The item under consideration is described as an automotive air conditioning filter, which is a component of the automotive heating, ventilation, and air conditioning (HVAC) system designed to clean the air entering the vehicle’s interior. The device filters out dust, pollen, mold, bacteria, and other airborne particles, thereby improving the air quality inside the car. The filter is usually located behind the glove compartment or under the dashboard. The automotive air conditioning filters are assembled in Thailand using components from Thailand and China. The Thai components include the origami and the outer box. The Chinese components include the filter material, edge strip, hot melt adhesive, double-layer blister film, and some of the packing that includes the color box, instruction manual, and labels. The assembly process occurs in Thailand and includes ten steps. The process starts with the origami, which is made on a reciprocating origami machine. Next, the ultrasonic welding and manual edging and trimming is undertaken. Then, the edges are automatically trimmed and beveled. The back glue is then applied before spraying coding, plastic sealing, and final packaging. 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 automotive air conditioning filter, it is our opinion that the manufacturing and assembly process performed in Thailand is not considered complex. In this instance, the Chinese filter paper is the primary filtering component of the finished filter. While the paper is pleated in Thailand and a few other minor components are added, the paper does not become a new article with a new name, character, and use. Therefore, in our opinion, the country of origin of the automotive air conditioning filter is China, which is where the filter paper 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) James Forkan Acting Director National Commodity Specialist Division