The country of origin of a reverse osmosis water system

N354794 October 29, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Matthew Bock Bock Trade Law 53 State Street, Suite 500 Boston, MA 02109 RE: The country of origin of a reverse osmosis water system Dear Mr. Bock: In your letter dated October 8, 2025, on behalf of your client, Cloud Water Filter, LLC, you requested a country of origin ruling on a reverse osmosis water system. Descriptive literature was provided for our review. This ruling is similar to New York ruling N353301 (dated September 30, 2025); however, the U.S. manufacturing processes have been updated to include the creation of the filters in addition to the permeate pump and printed circuit board assembly (PCBA). The item under consideration is the Cloud Reverse Osmosis (RO) Smart Water Filtration System, which is a Bluetooth-connected, sensor-driven, under-sink reverse osmosis (RO) system. The Cloud RO distinguishes itself from traditional water filters due to its integrated internet of things (IoT) technology, centered around a proprietary base unit that includes a PCBA. The device features real-time sensors that measure and transmit total dissolved solids (TDS), pressure, and flow monitoring. The embedded microcontroller manages system behavior and allows the system to operate. A companion mobile app allows users to monitor water quality, receive alerts, and track filter life. The data transmission from the mobile app is sent to the Cloud server allowing remote system monitoring and automated diagnostics. The Cloud RO Smart Water Filtration System works by pushing tap water through a multi-stage filtration process. The first filtering process is a sediment filter that uses a 5-micron polypropylene filter to trap larger particles such as dirt and rust. The second stage is a carbon filter, which is a 1-micron carbon block filter that removes chlorine, VOCs (volatile organic compounds), and other disinfectants. This filter also has anti-scale properties to protect the RO membrane. Finally, a semi-permeable RO membrane is used, which removes up to 99% of contaminants, including PFAS (Per- and Polyfluoroalkyl Substances), lead, and fluoride by forcing water molecules through while blocking larger impurities. The system then adds back healthy minerals through a remineralization filter for better taste and alkalinity. A hydraulic pump increases pressure, sensors track water quality via a dedicated app, and a storage tank ensures purified water that is immediately available through a separate faucet. The manufacturing starts in the United States with the creation of the printed circuit board assembly (PCBA). The process starts with the integration of control electronics and the user interface. This includes the design and validation of the printed circuit board (PCB) schematic and layout, including power regulation, microcontroller selection, sensor calibration, and Bluetooth tuning. The next step involves the development of firmware that leverages the microcontroller to control the functionality, including storage protocols, broadcast frequency, and device operability. It also defines the flow of the mobile interface. Next, the bill of materials is developed along with the work instructions. Once the procedure is set, the manufacturing begins with the population and soldering of the components using surface mount technology (SMT). This involves the placement of microcontrollers, memory chips, resistors, capacitors, and other devices. Several connectors are also attached with a through-hole placement and then reflow soldering for SMT components is completed using a temperature-controlled oven. This is followed by cleaning, testing, and adding the protective potting compound. Additionally, in the United States, the permeate pump, RO membrane, pre-carbon block filter, and post-carbon block filter are all manufactured prior to shipping to China where they are combined with the remaining Chinese components. The Chinese components include the total dissolved solids (TDS) sensor, pressure sensor, tank, faucet, cables, shell, base, top cap, filter sleeve, manifolds, and numerous other small parts. In total, there are 93 different components included in the manufacturing process. In China, the process starts with the assembling of the conductive blocks and microswitches and then moves into installing the assembly bracket wrench. This involves carefully placing the bracket and combining it with a spring before screwing it in place. Next is the installation of the microswitch using a screw and fastening the waterway plate. The electrical control plate is then placed on the right side and assembled before attaching the wiring harness. Next, the permeate pump is placed and connected with the permeate pump connector, permeate pump outlet, and waterway board connector. Then, all the terminals are hot-melt glued. Several tests are then conducted to ensure all the components are watertight and working properly. Next, the components are cleaned before fastening the bottom and adding floor mats. The filter sleeve and magazine are added and fastened into place. The filters are then assembled, and the battery and clips are added. Finally, the overall unit is inspected, and the top cap is installed completing the manufacturing process. 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 country of origin of the Cloud Reverse Osmosis Smart Water Filtration System, it is our opinion that the manufacturing process occurring in China is not considered complex. It predominately involves simple assembly by snapping, screwing, connecting, and gluing different parts into place. We believe that the U.S. origin PCBA, permeate pump, RO membrane, pre-carbon block filter, and post-carbon block filter provide the essence of the finished RO filtration system. These items are not transformed into a new and different articles with a name, character, and use that is different when combined with the Chinese components. Accordingly, the country of origin of the Cloud Reverse Osmosis Smart Water Filtration System will be the United States, which is where the PCBA, permeate pump, RO membrane, pre-carbon block filter, and post-carbon block filter are 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division