The country of origin of a cool mist humidifier

N352841 September 23, 2025 OT:RR:NC:N4:410 CATEGORY: Origin Jo-Anne Daniels Jo-Anne Daniels DBA Trade Resources & Associates 230-B Tyson Avenue Paris, TN 38242 RE: The country of origin of a cool mist humidifier Dear Ms. Daniels: In your letter dated August 25, 2025, you requested a country of origin determination on behalf of your client, Crane USA Inc., on a humidifier for purposes of current trade remedies. The merchandise at issue is identified as Cool Mist Humidifier (humidifier). It consists of a removable water tank, cover top assembly, minimum/maximum adjustment, green LED operational, and red LED low water level indicator. You present a manufacturing scenario as described below: The ultrasonic nebulizer will be sourced and manufactured in South Korea. The ultrasonic nebulizer is a piezoelectric ceramic element, and its function is to convert electrical energy into ultrasonic mechanical vibration and create aerosolized water droplets without heat. Its performance depends on crystal microstructure, dimensional accuracy, and precise resonance tuning. The production process of ceramic devices in ultrasonic nebulizers involves powder preparation, forming, sintering, electrode deposition, poling, assembly, and testing. You emphasize that the precision of thickness and resonance tuning is critical because the efficiency of nebulization depends strongly on how well the ceramic resonates at the driving frequency. The production of the ultrasonic nebulizer comprises of the following steps: Ceramic powder formulation and pressing/sintering under tightly controlled thermal profiles to achieve the target density, grain size, and piezoelectric constants. Electrode deposition and patterning with tight tolerances to ensure uniform excitation. Dicing, lapping, and polishing to micron-level flatness for efficient coupling and stable resonance. Electrical polarization and frequency tuning to the target ultrasonic band to control droplet size distribution and output. Protective surface treatments and sealants to mitigate moisture/mineral attack in continuous water exposure. Advanced QC using impedance analysis and laser vibrometry to verify resonance frequency, Q-factor, and amplitude. The controller is also produced in South Korea. The Controller provides high-frequency drive signals and system control. It must generate a stable ultrasonic oscillation, manage power, and maintain safety and reliability in a humid environment. The key manufacturing/engineering operations in the making of the control include: High-frequency driver design and PCB layout practices that minimize parasitic inductance/capacitance and Electromagnetic Interference (EMI) FR-4 stack-up selection and copper geometry optimized for current density and thermal management. Surface Mount Technology (SMT) assembly with precision placement, reflow profiling, and selective soldering for mixed technology. Functional and safety testing (In-Circuit Testing (ICT)/functional test, overload/short protection verification) at operating voltage/current. Conformal coating to protect against condensation and ionic contamination; coating selection and application method (spray/dip/selective) must balance dielectric strength and reworkability. The balance of the components, such as the cover, handle, water tank, tank cover, cock, valve screws, fan, nuts, spring, adaptor, and metal screw assemblies, are made in China. The final assembly occurs in China. The operations in China consist of the plastic injection molding of the plastic components, inspection of the molded part, and application of the silk screen or laser print on the plastic surfaces. In the next step, the PCB’s control panel, metal screw assembly, fan, and ultrasonic nebulizer are assembled into the base unit. The subsequent step of the assembly is a high-voltage insulation testing of the base unit and the power adaptor, followed by functional quality control testing of the assembled unit. The next step is the ultrasonic welding of the top and bottom sections of the water tank, and water leak testing of the fully assembled water tank. The last step is the final cleaning and complete assembly of all the components that are packaged into a retail box and master shipping carton. When determining the country of origin for purposes of applying current trade remedies under Section 301 and other duties, 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 country of origin of the humidifier, we are of the view that the ultrasonic nebulizer and the controller are made in South Korea, the manufacturing process including the SMT process along with other assembly operations in South Korea is complex and meaningful. In addition, these components are the most important or critical which impart the character of the product. They have pre-determined use before imported to China. The operations in China do not substantially transform these components. Accordingly, the country of origin of the humidifier is South Korea. 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 Michael Chen at michael.w.chen@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division