The country of origin of automotive air filters

N352564 September 8, 2025 N352564 OT:RR:NC:N1:105 CATEGORY: Origin Anchalika Prachakool QAP Filter (Thailand) Co., Ltd. 98/3 Moo 11, Nongbua Subdistrict, Bankhai District, Rayong Province 21120 Thailand RE: The country of origin of automotive air filters Dear Ms. Prachakool: In your letter dated August 18, 2025, you requested a country of origin ruling on automotive air filters. The items under consideration are described as automotive air filters, which are components 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 WT213185TH and WT215053TH-1 models are rectangular and square versions of the filter with a frame holding the filtering material in place. The automotive air conditioning filters are assembled in Thailand using components from the United States, China, and Thailand. The Thai components include the filter element (structural support and housing for the media), slitted media block, box, wood pallet, and other packaging materials. The Chinese components encompass the sealing adhesive, metal mesh, polyether polyol, isocyanate, and some of the packaging including the color box and labels. The filter media is from the United States. The assembly process occurs entirely in Thailand and includes seventeen steps. The process starts with the media humidification of the textile material, followed by flow-channel shaping of the raw material using press roller machines. After the material is shaped, an adhesive injection machine is used to internally seal the filter material together. A media pleating machine folds or pleats the filter media for the next step, shaping the filter element by utilizing a cooling channel. A worker then manually cuts the media using a slitting knife in preparation for the metal mesh bonding step, a semi-automatic process undertaken by a gluing machine. Once glued, a polyurethane (PU) tooling heating process prepares the pleated filter media for adhesion to the rigid structure of the filter. Next, the filter media is brought to a two-component adhesive injection machine where A (polyol) and B (isocyanate) PU adhesives are mixed to initiate a chemical reaction to create a strong, durable bond and rigid structure that is used to fix the pleated filter media within the frame. The filter forming process continues with the application of PU foam, element heating, flash trimming, pleating stabilization adhesive injection, and spraying data code. 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 automotive air filters, it is our opinion that the manufacturing and assembly process performed in Thailand is not considered complex. In this instance, the United States filter media is the primary filtering component of the finished filters. While the media is pleated in Thailand, it does not become a new article with a new name, character, and use. Therefore, in our opinion, the country of origin of the WT213185TH and WT215053TH-1 automotive air conditioning filters is the United States, 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