The country of origin of a heat pump

N354369 October 23, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Yunxuan He Midea Intelligent Manufacturing (Thailand) Co., Ltd. V43M+PQ, Makham Khu, Nikhom Phatthana District Rayong 21180 Thailand RE: The country of origin of a heat pump Dear Ms. He: In your letter dated September 29, 2025, you requested a country of origin ruling on a heat pump. A description of the assembly processes was provided in your submission. The product at issue is a Light Commercial Rooftop Unit Packaged Heat Pump, model number UL-WKR160B/MN10X-134A. The heat pump consists of a cabinet that encases an evaporator, a condenser, a compressor, a blower assembly, a reversing valve subassembly and an optional heater kit. The heat pump, which is designed for residential or certain commercial applications, is a self-contained unit that cools spaces and provides heat by reversing the refrigeration cycle. The system is intended to be installed on rooftops or ground-level slabs. With respect to origin, the final assembly of the heat pump occurs in Thailand using components from Thailand, China and South Korea. Prior to the final assembly, various subassemblies are produced in Thailand. Five different plates (partition, protective, cover, and condenser fixing plates), an evaporator connecting plate subassembly, three cover subassemblies and two internal plate subassemblies are formed using a stamping and a bending process. Afterwards, a sponge is installed onto the plate, and when required the subassembly is coated. The beam welded subassembly is formed by stamping sheets and welding a strip onto a sheet. Two column subassemblies are formed by stamping and bending steel plates. Next, a strip, a pipe joint installation box and a separating plate are welded onto a plate. The subassembly is then coated, and a sponge is installed. The air duct subassembly is formed by screwing a duct reinforcement support plate, an auxiliary heating cover plate, a duct enclosure plate, a fan mounting plate, and a duct connection plate to each other. Subsequently, a sponge is installed in place. The chassis subassembly, which forms the bottom structure of the unit, is produced by stamping and bending plates. Next, a compressor base weldment, a reinforcement plate, a crossbeam, a chassis, and a waterproof panel are aligned and fastened in position using screws. Subsequently, a condenser anti-slip pad is installed, and lastly, a fiberglass wool cover is installed. The circuit subassembly, which consists of a piston throttling valve, a suction pipe, and a four-way-valve, is produced by cutting, bending, flaring and necking copper tubes. These tubes are then welded into assemblies. The four-way-valve is secured using self-adhesive rubber pads. The production of the heat exchange subassemblies begins by threading the side plates and fins together and the insertion of long U-tubes. After tube expansion, both components are dried in an oven. Semi-circular tubes are then welded at designated positions, and the inlet and outlet pipe assemblies are welded in place. The completed units function as an evaporator and a condenser, which is subjected to an additional bending step after the previous welding process. The production of the electrical control box subassembly begins by coating a welded box. Once coated, a main board, a module board assembly, a gas main board, a transformer and a relay are fixed into position within the box. Finally, appropriate connections are made. The final assembly starts by bolting a compressor from South Korea onto the chassis, which is followed by affixing a liquid storage cylinder. An air duct assembly is then mounted and secured in position using screws, followed by the installation of a sponge. Structural components, including a piping support plate and a drip pan, are installed and fixed to the chassis. A drip pan drainpipe is then attached using hose clamps and screws. Next, an evaporator is fastened securely to the chassis, and a middle partition and wire shield are installed. Sealant is appropriately applied. Afterwards, valve assemblies are inserted and welded in place, which is followed by fixing a condenser in place and the welding of a throttling valve assembly. Next, a pipe temperature sensor is installed, a motor is bolted in place, and a fan is attached to the motor. Subsequently, protective plates and a control box are installed, followed by the installation of inner side panel subassemblies. Wiring connections are completed, and the motor is assembled with the top cover grille using bolts. Lastly, a top cover and side panels are screwed in place, and an electrical control box cover plate is installed. Each heat pump is subjected to tests and inspections, and afterwards, labeled and packaged. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters (HQ) 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). In this instance, components sourced from China, South Korea and Thailand, including subassemblies that contribute to the change of temperature process (an evaporator and a condenser) and the chassis, are assembled to each other in Thailand to produce a heat pump. CBP addresses the origin of a heat pump in HQ Ruling Letter H320037, dated November 18, 2021. In this ruling, the country of ruling of the unit was based on the origin of the components that make up the cooling system and the final assembly processes. In applying the same origin rationale, we find the origin of the heat pump is Thailand. 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 Sandra Martinez at sandra.martinez@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division