The country of origin of automotive air filters

N355894 December 2, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Yuting He QAP Automotive Industries (China) Ltd. No.851, Zhongcheng Road, Fengcheng Town Fengxian District Shanghai, 201400 China RE: The country of origin of automotive air filters Dear Ms. He: In your letter dated November 7, 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 WT213092-2, WT213159NX, WT215057-3, WT215075U, WT221005-2 models are rectangular versions of the filter with a frame holding the filtering material in place. The automotive air conditioning filters are assembled in China using components from Germany and China. The Chinese components include the filter element (structural support and housing for the media), slitted media block, sealing adhesive, metal mesh, polyether polyol, isocyanate, and some of the packaging including the color box, labels, wood pallet, and paper angle beads. The filter media is the sole German component. The assembly process occurs entirely in China and includes sixteen steps. The process starts with the humidification of the media material, which allows high temperature steam to facilitate the media to absorb moisture and soften. After, the media is sent for flow channel shaping using a press roller machine. This process creates reinforcing ribs for the media and distributes it into equal areas. The filter media continues to move onward for internal sealing adhesive injection, where adhesive is added to the edge of the filter to make the adhesive adhere strongly to the surface. A media pleating machine folds or pleats the filter media for the next step, shaping the filter element by utilizing a cooling channel. Using a slitting knife, a worker manually cuts the media from a three-dimensional filter block into small filter blocks of equal volume. The filter media is then passed on to a curing oven before the polyurethane (PU) mold continues onward to the thermostatic oven where it is baked. The filter forming process continues with flash trimming, adhesive injection, printing product identification, laminating, and packaging. 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 China is not considered complex. In this instance, the German filter media is the primary filtering component of the finished filters and is the most expensive portion of the finished product. While the media is pleated in China, it does not become a new article with a new name, character, and use. Therefore, in our opinion, the country of origin of the WT213092-2, WT213159NX, WT215057-3, WT215075U, WT221005-2 automotive air conditioning filters is Germany, which is where the filter media 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division