The country of origin of an automotive air filter

N352766 September 12, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Anchalika Prachakool QAP Filter (Thailand) Co., Ltd. 350/40 Moo 6, Surasak Sriracha 20110 Thailand RE: The country of origin of an automotive air filter Dear Mr. Prachakool: In your letter dated August 22, 2025, you requested a country of origin ruling on an automotive air filter. Descriptive literature was provided for our review. The item under consideration is described as an automotive air filter, which is a component of the automotive heating, ventilation, and air conditioning (HVAC) system designed to clean the air entering the vehicle’s interior. The device filters 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 WT212094TH model is a rectangular version of the filter with a frame holding the filtering material in place. The automotive air conditioning filter is assembled in Thailand using components from Thailand and China. The Thai components include the filter media, filter element, slitted media block, PP melt-blown microfiber, and various packaging materials. The Chinese components include the fiber base paper, sealing adhesive, polyether polyol, isocyanate, polyester fiber, color box, and label. The assembly process occurs entirely in Thailand and includes seventeen steps. The process starts with the composite filter media materials layered together using an ultrasonic composite machine. The impregnated wood pulp fiber base paper serves as the substrate material, which is combined with melt-blown microfiber through an ultrasonic bonding process to create composite filter paper with enhanced filtration performance meeting required specifications. A machine then splits the composite media into proper dimensions. Next, humidification of the media material, followed by flow-channel shaping of the raw material using press roller machines occurs. 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. Using a slitting knife, a worker manually cuts the media from a three-dimensional filter block into small filter blocks of equal volume. The PU mold continues onward to the thermostatic oven where it is baked. 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 filter, it is our opinion that the manufacturing and assembly process performed in Thailand is considered complex. In this instance, the primary filtering components, including the paper from China and the media from Thailand, need to be ultrasonically combined in Thailand. In our opinion, while many of the additional steps include simple assembly, the ultrasonic combining creates a new article with a new name, character, and use. Therefore, in our opinion, the country of origin of the WT212094TH automotive air conditioning filter is Thailand, which is where the fiber base paper and filter media is ultrasonically combined. 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