The country of origin of automotive air filters

N352956 September 16, 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 automotive air filters Dear Ms. Prachakool: In your letter dated August 27, 2025, you requested a country of origin ruling on automotive air filters. The items under consideration are described as automotive air filters, which are a component 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 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 Italy, Thailand, and China. The Chinese components include the metal mesh, sealing adhesive, polyether polyol, isocyanate, polyester fiber, color box, and label. The Thai components include the filter element, slitted media block, and various packaging materials. The filter media is made in Italy. The assembly process occurs entirely in Thailand and includes sixteen steps. The process starts with the humidification of the media 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. 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 polyurethane 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 not considered complex. In this instance, the Italian filter media is the primary filtering component of the finished filters. While the media is pleated in Thailand and a few other minor components are added, the media does not become a new article with a new, character, and use. Therefore, in our opinion, the country of origin of the WT213185TH and WT215053TH-1 automotive air conditioning filters is Italy, 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