The country of origin of automotive air conditioning filters

N354015 October 2, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Pitchaya Pradbkaew QAP Filter (Thailand) Co., Ltd. 98/3 Moo 11, Nongbua, Bankhai Rayong 21120 Thailand RE: The country of origin of automotive air conditioning filters Dear Ms. Pradabkaew: In your letter dated September 22, 2025, you requested a country of origin ruling on automotive air filters. Descriptive literature was provided for our review. The items under consideration are described as automotive air filters, which are components of an 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 filters are usually located behind the glove compartment or under the dashboard. The WT321044C, WT311028C, WT321043C, WT312021C, and WT325023C models are rectangular versions of the filter with a frame holding the filtering material in place. The automotive air conditioning filters are assembled in Thailand using components from Thailand and China. The Chinese components include the polypropylene (PP) filter layer, carbon-clad composite layer, hot-melt adhesive, short and long frames, gasket, and some of the packaging materials including the color box and label. The Thai components consist of the functional element, filter media, and packaging materials such as the blister film, instruction manual, outer box, cardboard, and paper angle bead. The assembly process occurs entirely in Thailand and includes nineteen steps. The process starts with the spray glue composite machine. Hot-melt adhesive is heated and melted in a glue tank, before the machine’s nozzle sprays the adhesive onto the surface of the carbon fabric substrate. It is then bonded to the PP filter layer that forms the paper filter. The paper filter roll is sent for media cutting and onward to a slitting machine for slitting the non-woven fabric. A media pleating machine then folds or pleats the filter media for the next step, shaping the filter element by utilizing a cooling channel. Functional element shaping then occurs using a heat curing machine. A worker then manually cuts the media using a slitting knife in preparation for the functional element self-sealing step which utilizes an ultrasonic welding machine. The process continues onward to the filter element shaping stage where a worker using a shaping tool forms the filter element. A bevel cutting machine cuts the bevel into shape before the application of the back gum using an adhesive injection machine, long and short side frame bonding using a bonding machine, gasket bonding and trimming, 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 filters, it is our opinion that the manufacturing and assembly process performed in Thailand, including the creation of the filtration media, transforms the Chinese articles into a complete automotive air conditioning filter. The Thai-origin filter media, when permanently combined with the PP filter layer and the carbon-clad composite layer creates the primary filtering component of the finished filters. Accordingly, in our opinion, the country of origin of the WT321044C, WT311028C, WT321043C, WT312021C, and WT325023C automotive air conditioning filters is Thailand, which is where the primary filtering component 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 Designated Official Performing the Duties of the Division Director National Commodity Specialist Division