The country of origin of filter cartridges

N352638 September 12, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Karl Means Miles & Stockbridge P.C. 1201 Pennsylvania Avenue, 9th Floor Washington, DC 20004 RE: The country of origin of filter cartridges Dear Mr. Means: In your letter dated August 19, 2025, on behalf of your client, Membrane Platforms, LLC, you requested a country of origin ruling on filter cartridges. Descriptive literature was provided for our review. The items under consideration are described as filter cartridges, which are devices designed specifically for use in applications requiring hydrogen separation from hydrogen-based gas streams. The filter cartridges are intended to process gas mixtures from refineries, chemical, and petrochemical plants. Each filter fits inside a module (housing) and multiple modules are used in a system installed at commercial plants. The gas separation filter works on the principle of selective permeation through the membrane fibers, which exploits the difference between the pressure of the gas on the retentate side (the interior of the hollow fibers) and the permeate side (the exterior of the hollow fibers). The hollow membrane fibers are specially designed to withstand high differential pressures and allow certain gases to permeate the membrane walls while the remainder is collected at high pressure as the retentate stream. Membrane material and configuration are tailored to each application to achieve the optimum trade-off between purity and recovery for the target gas, in this case hydrogen. In the process, the filters remove impurities such as methane, carbon dioxide, argon, and nitrogen. The membranes are comprised of manufactured small-diameter porous capillaries or hollow fibers. Hollow membrane fibers may be manufactured from a variety of industrial polymers (plastics) such as cellulose acetate, polysulfones, polyetherimide, and polyimides. The membranes subject to this ruling are made of polyimides, which is the polymer used for the gas separation membranes. Each gas filtration cartridge is manufactured in the United Arab Emirates (UAE) from components from Russia, Germany, China, the U.S., and the UAE. The polymer fiber is produced in Russia while the bushing is made in Germany. The U.S. components include the amorphous fluoropolymer, heat-transfer and electronics-testing fluid, resin, epoxy, and curing agent. The Chinese components include the mandrel screen, cap screen and pot screen. Finally, the UAE components include the machined mandrel, solid pot plug, cap end insert, and various O-rings. The first step in the manufacturing process includes setting up and tensioning of the fiber reels for winding around the filter mandrel followed by the assembly of the mandrel. Next, the winder is set up for proper winding around the mandrel (Interflow surface channel and flow distributor layer), which is critical to achieve the necessary separation according to specification for the specific application. Next is the winding step, which involves the programming and helical winding of the fiber around the mandrel before drying and heat treating. Next, the terminal ends are hot wire cut, and the flow distribution screen is installed. The fiber ends are then sealed and epoxied before machining of the permeate gas slots in the cap and surface planing of the end caps. Next, a specialized coating solution is circulated through the cartridge to coat the fiber surfaces followed by another dry heating treatment to dry both the cartridge and the fiber surface coating. Finally, the cartridge undergoes quality control and pressure testing before adding the protective exterior casing, O-rings, and gaskets. 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 filter cartridges, it is our opinion that the manufacturing and assembly process performed in the UAE is considered complex. Numerous steps are needed to transform the individual components from Russia, China, Germany, and the U.S. into a filter cartridge in the UAE. The individual components each have a change in name, character, and use. Therefore, in our opinion, the country of origin of the filter cartridges is the UAE, which is where the assembly and manufacturing processes occur, and the Russian, Chinese, German and U.S. components are transformed into finished filter cartridges. 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