The country of origin of cabin air filters

N351809 August 7, 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 cabin air filters Dear Ms. Prachakool: In your letter dated July 30, 2025, you requested a country of origin ruling on cabin air filters. Descriptive literature was provided for our review. The items under consideration are described as cabin air filters (model numbers WT321043C and WT312021C), which are a component of the automotive heating, ventilation, and air conditioning (HVAC) system designed to clean the air entering the vehicle’s interior.The devices filter out dust, pollen, mold, bacteria, and other airborne particles, improving the air quality inside the car. The filter is usually located behind the glove compartment or under the dashboard. The two models are substantially similar in design and construction and are only differentiated by a slight change in shape. The cabin air filters are assembled in Thailand using components from Thailand and China. The Thai components include the filter element, double layer blister film, instruction manual, and some of the packaging including the outer box, wood pallet, cardboard, and paper angle bead. The Chinese components include the filter media, short side frame, long side frame, hot melt adhesive, gasket, and some of the packaging including the color box and labels. The assembly process occurs in Thailand and includes seventeen steps. The process starts with the non-woven fabric slitting before utilizing a media pleating machine to fold or pleat the filter media. Next is the functional element shaping before the media is slit and self-sealed on an ultrasonic welding machine. The next step is shaping the filter element, element bevel cutting, and applying the back gum with an adhesive injection machine. Next, the long and short side frames are bonded before manually trimming and automatic bonding and trimming. Next, the gasket is bonded before spraying the identification code onto the filter using an inkjet printer. Finally, the filter is wrapped in plastic using a laminating machine and sent along a conveying line for placement and packing in a cardboard box. 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 cabin air filters, it is our opinion that the manufacturing and assembly process performed in Thailand is not considered complex. In this instance, the Chinese filter media is the primary filtering component of the finished filters. While the media is pleated in Thailand and a few other minor components are added, the media does not become a new article with a new name, character, and use. Therefore, in our opinion, the country of origin of the WT321043C and WT312021C cabin air filters is China, which is where the filter media 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