The country of origin of a compressor

N355567 November 26, 2025 OT:RR:NC:N1:102 CATEGORY: Origin James Amyx Sandler, Travis & Rosenberg, P.A. 5835 Waterford District Drive, Suite 200 Miami, FL 33126 RE: The country of origin of a compressor Dear Mr. Amyx: In your letter dated October 31, 2025, on behalf of your client, Universal Air Conditioner, LLC., you requested a country of origin ruling on a compressor to apply current trade remedies and for marking purposes. The product at issue is a compressor, SKU 68510505. The compressor is designed to be installed in a motor vehicle and connected to the belt system of the engine. Once powered, the pistons of the compressor’s swashplate subassembly transfer rotational power within the planetary disc subassembly, which moves back and forth. The resulting motion pressurizes and displaces gas used in the air conditioning system. With respect to origin, the final assembly of the compressor occurs in Taiwan using components primarily from Taiwan and China. Prior to the final assembly, a cylinder block, rear and front covers, a rear cover plate and certain subassemblies are produced in Taiwan. To produce the cylinder block, rear and front covers, and the rear cover plate, raw metal from Taiwan is melted in a furnace and subsequently pressed into a mold. Afterwards, the mold is deburred and shot blasted. Next, the covers, rear cover plate and cylinder block are machined. During the machining, the threaded holes and mounting grooves are formed using boring and facing operations. The production of the swashplate subassembly begins by sourcing a swashplate casting from China. In Taiwan, the surfaces of the plate and shaft are turned, and holes are incorporated into the plate. The inclined surfaces are milled, and the working surfaces are ground. Afterwards, the swashplate is heat treated and anodized. To form the swashplate seat, raw material from China is forged, heat treated, and machined roughly and precisely to create the oil channels and mounting holes. The seat is then quenched and tempered. To form the main shaft and shaft arm, raw material is sourced from China and forged. Afterwards, the forgings are quenched and tempered, followed by the quenching and tempering of the outer diameter and ends. The ends are drilled, machined, hardened and coated. To form the pulley, the outer surfaces of a forging blank from China are turned. The belt grooves are machined, a central hole is drilled, and all edges are chamfered. The burrs on the edges are removed. The pulley is then hardened and coated. To form the coil, copper wire from China is connected to electrical terminals using a soldering process. Subsequently, the coil is inserted into a housing and encapsulated with epoxy. During the final assembly, a shim is inserted into a swashplate seat and swashplate and tightened using a machine. Then, a return spring is installed into the bottom of a main shaft arm. Afterwards, a connecting block and two shaft pins are inserted and pressed in place. Next, a pin, a retaining ring and sleeve are manually inserted and pressed together. The process continues by threading a valve gasket and pressing it into a check valve, which is then screwed onto a rear cover. Bearings are then pressed in position, and a seat ring and washers are inserted into the cylinder block. Then, a main shaft and piston-hemispherical shoe are installed onto the swash plate, which is subsequently inserted into the cylinder block. Once lubricant is applied, dowel pins, a gasket, a bearing and a front cover are installed. Next, a shaft seal and ring are pressed onto the shaft end of the compressor assembly, and a rear valve subassembly is then completed and installed into the cylinder block. Subsequently, a rear cover is bolted in place, a valve plate assembly is installed and oil is filled. Afterwards, a coil subassembly and a pulley are pressed onto the front cover, and a wire clamp is screwed in place, which is followed by the fastening of a drive disk onto the pulley hub. The finished compressor is packaged ready for shipment. 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 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). Additionally, 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). Part 134 of the U.S. Customs and Border Protection (CBP) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. 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. CBP has held that whether an assembly process is sufficiently complex to rise to the level of a substantial transformation is determined upon consideration of all the operations that occur within that country. Here, forged components are machined and finished in Taiwan, including the swashplate and planetary disc subassemblies, which are then combined with other components such as a Taiwanese manufactured cylinder block and rear head to form a compressor in Taiwan. When considering the totality of the circumstances, this office finds that the processes that occur in Taiwan, taken as a whole, are sufficiently complex and meaningful as to result in a substantial transformation, such that the non-originating components lose their individual identities and become an integral part of a new article, possessing a new name, character and use. Based on the processes described in the submission, we find the country of origin of the compressor is Taiwan. 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division