The country of origin of a compressor

N352067 September 3, 2025 OT:RR:NC:N1:102 CATEGORY: Origin James Amyx Sandler, Travis & Rosenberg, P.A. 5835 Waterford District Drive, Suite 200 Miami, FL 33126 RE: The country of origin of a compressor Dear Mr. Amyx: In your letter dated August 5, 2025, on behalf of your client, Universal Air Conditioner, LLC., you requested a country of origin ruling on a compressor to apply current trade remedies and for marking purposes. The product at issue is a compressor, model number SD7H15. The compressor is designed to be installed in a motor vehicle and connected to the belt system of the engine. Once powered, the pistons of the compressor’s swashplate subassembly transfer rotational power within the planetary disc subassembly, which moves back and forth. The resulting motion pressurizes and displaces gas used in the air conditioning system. With respect to origin, the final assembly of the compressor occurs in Malaysia using components from China and Malaysia. Prior to the final assembly, the cylinder block, the rear head and certain subassemblies are produced in Malaysia. To produce the cylinder block, raw metal from China is melted in a furnace and subsequently pressed into a mold. Afterwards, the mold is deburred, heat treated, brushed and shot blasted. Next, the front and rear planes undergo rough turning, and the piston holes and end face are machined, which is followed by reaming, milling, drilling and tapping processes. Machining continues and subsequently the oil plug holes and grooves are subjected to turning. The finished cylinder block is then cleaned. The rear head is formed using melting, casting, deburring, heat treating and shaping processes. The high- and low-pressure holes and end faces are then finished, the intake and exhaust holes are bored, and the planes are milled, drilled and tapped. The production of the swashplate subassembly begins by sourcing a swashplate casting from China. In Malaysia, the surfaces of the plate and shaft are turned, and holes are incorporated into the plate. The compressor shaft is then mechanically pressed into the swashplate subassembly and adjustments are completed using a drilling machine. A pin is then pressed into the subassembly, and the plate of the subassembly is machined on its flat surfaces. To produce the planetary disc subassembly, Chinese sourced piston rings are mechanically pressed on a piston. Next, the piston and connecting rod from China are riveted together using a hydraulic press. Gears are then pressed into the planetary disc guide rings and afterwards combined with the connecting rod assembly to form the planetary disc subassembly. Subsequently, the piston subassembly is joined to the ball socket of the planetary disc and pressed in placed. During the final assembly, the planetary disc assembly is mechanically installed in the cylinder block, and a front cover is pressed against a main bearing, followed by the installation of a swashplate subassembly. Then, the necessary connection to the planetary disc is completed. Next, a bearing is installed, the front cover assembly is bolted to the cylinder body, and a shaft seal and retaining ring are pressed into the cylinder block. A semicircular key is also installed, and a valve plate, along with the respective gaskets and reeds, are bolted in place. Afterwards, a rear head is affixed to the cylinder block with bolts, which is followed by the injection of oil and nitrogen. In sequence, an O-ring is installed, and a coil is fixed in the front head with a spring clip. Subsequently, a bearing is pressed into a pulley from China, an adjustment plate is inserted, and a suction cup is bolted in place. Finally, the wire clamp is installed, and the finished compressor is packaged ready for shipment. Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection Regulations (19 CFR 134) implements the country-of-origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). CBP has held that whether an assembly process is sufficiently complex to rise to the level of a substantial transformation is determined upon consideration of all the operations that occur within that country. Here, components are assembled together in Malaysia to produce subassemblies, including the swashplate and planetary disc subassemblies, which are then combined with other components such as a Malaysian manufactured cylinder block and rear head to form a compressor in Malaysia. When considering the totality of the circumstances, this office finds that the processes that occur in Malaysia, taken as a whole, are sufficiently complex and meaningful as to result in a substantial transformation, such that the non-originating components lose their individual identities and become an integral part of a new article, possessing a new name, character and use. Based on the processes described in the submission, we find the country of origin of the compressor is Malaysia. 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) Denise Faingar Acting Director National Commodity Specialist Division