The country of origin of a refrigerant recovery unit

N351922 August 27, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Alexandra Salzman The Inter-Global Trade Law Group PLLC 1156 Fifteenth Street NW, Suite 1101 Washington, DC 20005 RE: The country of origin of a refrigerant recovery unit Dear Ms. Salzman: In your letter dated August 1, 2025, you requested a country of origin ruling on behalf of your client, Value (Thailand) Co., Ltd. Descriptive information was provided in the submission. The product at issue is a refrigerant recovery unit. The unit, which is a composite machine, is designed to push liquid refrigerant into an external recovery tank and is comprised of an outer casing that primarily encloses a motor, a compressor, a condenser, a fan, and a filter. In operation, a motorized compressor suctions refrigerant vapor from refrigeration equipment or an air conditioning unit, the refrigerant is filtered of solid impurities, and the condenser and fan expel heat, reducing the temperature of the refrigerant. With respect to origin, the final assembly occurs in Thailand using components sourced from China and a motor produced in Thailand. The assembly of the motor begins by winding copper wire from Thailand onto a stator core from Thailand. Tubing and sleeves are then placed over the copper wires, and additional wiring is soldered to the copper windings. Next, an electronic board is welded to the motor stator assembly, which is followed by the installation of a magnetic ring, a terminal block assembly and a back cover. Afterwards, magnets are bonded to the rotor shaft from Thailand, and a cover is installed over the shaft. Subsequently, a bearing is installed onto the shaft of the motor, and a front cover is pressed in place. Finally, the stator and rotor subassemblies are secured to each other using screws, resulting in a finished DC motor. During the final assembly, a fan air guide cover, a fan, and a coupling from China are assembled onto both ends of a motor and secured in place with screws. Mounting feet are then installed on both sides of the motor to form the motor subassembly. The motor subassembly and a compressor subassembly from China are screwed together. The baseplate and left group plates are installed onto the compressor feet, and a condenser from China is installed onto the compressor assembly. Wiring connections are then made, and a sensor is installed. Next, two gears and a control valve from China are installed, which is followed by the placement of the handle fixing frame to the motor and control valve. A hook is then joined to the right plate and afterwards installed onto the unit. A rubber-coated handle is installed onto the top plate. Subsequently, membrane keys are affixed onto the transparent panel, which along with a digital display board assembly from China, is secured to the front cover using screws. Additional wiring connections are completed. Then the front and back covers from China are aligned with the baseplate groups and screwed in place. As the aforementioned steps occur, a large knob is installed. The assembly process continues by soldering any remaining wires, and the installation of a retaining ring, and a filter screen from China. Once the unit passes testing and inspection, it is packaged with a drying filter from China. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, 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). Based on the scenario presented in the submission, the final assembly operations, which occur in Thailand do not result in a substantial transformation. The components are installed using processes that are rather simple and the components from China do not emerge with a new name, character, and use, different from that possessed by the components (e.g., compressor, condenser, filter screen, outer encasement) prior to the processing. Thus, based on the totality of the circumstances, the country of origin of the refrigerant recovery unit will be China. 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 Sandra Martinez at sandra.martinez@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division