The country of origin of automotive air conditioning filters

N352485 September 2, 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 automotive air conditioning filters Dear Ms. Prachakool: In your letter dated August 15, 2025, you requested a country of origin ruling on automotive air conditioning filters. Descriptive literature was provided for our review. The items under consideration are described as automotive air conditioning filters (model numbers WT312021C and WT321043C), which are components of an 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 filters are usually located behind the glove compartment or under the dashboard. The two models are only differentiated by a slight change in shape but are manufactured in a substantially similar way. The automotive air conditioning filters are assembled in Thailand using components from Thailand and China. The Thai components include filter elements and additional packaging as well as the double-layer blister film, instruction manual, blank outer box, pallet, cardboard, and paper angle bead. The Chinese components include the polypropylene protective layer, melt-blown efficiency layer, polyethylene terephthalate (PET) support layer, short side frame, long side frame, hot melt adhesive, gasket, and some of the packaging such as the color box and labels. The assembly process occurs in Thailand and includes nineteen steps. The process starts with the non-woven composite processing followed by the media cutting and non-woven fabric slitting. Next, comes the folding line pressing and media pleating before going to the heat curing machine for the functional element shaping. Then, the media is slit before being self-sealed on the ultrasonic welding machine. The next process includes the filter element shaping, element bevel cutting, application of the back gum, and the adding of the long and short side frames. The frame is then manually trimmed before the final automatic bonding and trimming and gasket bonding. Finally, the spray coding (adding the identification), plastic sealing, and final packaging complete the process. 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 filters, it is our opinion that the assembly process in Thailand, in combination with the creation of the filtration media, results in a substantial transformation of the individual components. Most notably, the creation of the filter media in Thailand creates the essence of the finished air conditioning filters. Therefore, in our opinion, the country of origin of the automotive air conditioning filters (model numbers WT312021C and WT321043C) is Thailand, 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) Denise Faingar Acting Director National Commodity Specialist Division