The country of origin of a cabin air filter

N353148 September 19, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Haifei Feng Joinhands Injection System (Thailand) Co. Ltd. 890/25 Moo 3 Khao Khan Song Subdistrict, Sriracha District Chonburi 20110 Thailand RE: The country of origin of a cabin air filter Dear Mr. Feng: In your letter dated September 2, 2025, on behalf of your client, Premium Guard Inc., you requested a country of origin ruling on a cabin air filter. Descriptive literature was provided for our review. The item under consideration is described as a cabin 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 automotive air conditioning filter is assembled in Thailand using components from Thailand and China. The Thai components include the hot melt used to bond the filter cloth and the side strips, filter element, plastic pellets (to create the plastic component), plastic support frame, and packaging. The Chinese components include the non-woven cloth and frame used to seal and support the product. The assembly process occurs in Thailand and includes eleven steps. The process starts with obtaining the Chinese raw material non-woven cloth. Then, the non-woven cloth is pleated and cut to size. Next, the paper core is assembled before an automatic edge sticking process. The additional edge material is then cut off, and all impurities are cleaned from the filter. Then, the polypropylene is injected before the plastic frame is adhered. Finally, the finished filter is packaged for shipment. 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 cabin air filter, it is our opinion that the manufacturing and assembly process performed in Thailand is not considered complex. In this instance, the Chinese non-woven cloth is the primary filtering component of the finished filter. While the cloth 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 cabin air filter is China, which is where the non-woven cloth 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