The country of origin of a receiver drier unit

N354470 October 24, 2025 OT:RR:NC:N84:105 CATEGORY: Origin Larissa Porto Reis de Andrade Mobile Climate Control 7540 Jane Street Vaughan L4K 0A6 Canada RE: The country of origin of a receiver drier unit Dear Ms. Porto Reis de Andrade: In your letter dated October 1, 2025, you requested a country of origin ruling on a receiver drier unit. Descriptive literature was provided for our review. The item under consideration is described as a receiver drier unit (T26-2150), which is a device designed to filter out contaminants and moisture in air conditioning systems. It is located on the high-pressure side of the air conditioning loop, typically between the condenser and the expansion valve. The device consists of a cylindrical tank with a solid core filter inside, which contains a drying agent. The final receiver dryer is assembled in Canada from three main components: (1) a Chinese-origin receiver dryer, (2) a Chinese-origin pressure switch, and (3) a United States-origin harness. The assembly process in Canada involves a simple process where the wire harness and pressure switch are added to the receiver dryer. Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other United States-Mexico-Canada Agreement (USMCA) provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in sections 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining the country of origin of a good for marking purposes, with the exception of textile and apparel goods which are subject to the provisions of 19 CFR 102.21. See 19 CFR 102.11. Applied in sequential order, 19 CFR 102.11(a) provides that the country of origin of a good is the country in which: (1) The good is wholly obtained or produced; (2) The good is produced exclusively from domestic materials; or (3) Each foreign material incorporated in that good undergoes an applicable change in tariff classification set out in Part 102.20 and satisfies any other applicable requirements of that section, and all other applicable requirements of these rules are satisfied. Since the subject merchandise is neither “wholly obtained or produced” nor “produced exclusively from domestic materials,” paragraphs (a)(1) and (a)(2) cannot be used to determine the country of origin of the receiver drier, and paragraph (a)(3) must be applied to determine the origin of the finished article. As the receiver drier unit is classified under subheading 8421.29, HTSUS, the applicable tariff shift requirement in Part 102.20 for the items under consideration states, in pertinent part: A change to subheading 8421.11 through 8421.39 from any other subheading, including another subheading within that group. The receiver drier under consideration herein is made of Chinese and U.S. components. Of significance here is the Chinese receiver drier (part number 26-1992) and the Chinese pressure switch (T25-3711) that are classifiable under subheading 8421.29 and heading 8536, HTSUS, respectively. As a result of the foreign status of the receiver drier (part number 26-1992), the Part 102.20 tariff shift requirement is not met and the origin of the receiver drier will be determined under Part 102.11(b), which states, in pertinent part: The country of origin of the good is the country or countries of origin of the single material that imparts the essential character to the good. It is the decision of this office that the receiver drier (part number 26-1992) is the principal component of the finished subject receiver drier unit (T26-2150). Furthermore, combining the receiver drier with the pressure switch and wire harness is a minor assembly production where the receiver drier is not substantially transformed as a result of the work performed in Canada. See Texas Instruments and National Hand Tool. As a result, at the time of importation into the United States, the country of origin of the receiver drier unit (T26-2150) will be China for origin and marking purposes. 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division