The country of origin of the SprintRay ProWash S Appliance

N357062 January 8, 2026 OT:RR:NC:N1:105 CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of the SprintRay ProWash S Appliance Dear Ms. Murrin: In your letter dated December 16, 2025, on behalf of your client, SprintRay Co. Ltd., you requested a country of origin ruling on the SprintRay ProWash S Appliance. Descriptive literature was provided for our review. The item under consideration is the SprintRay ProWash S Appliance, which is a sophisticated device designed for the automated washing and drying of 3D-printed dental models. It employs a two-stage mechanical jetting process, completing a full cycle in under nine minutes. The initial stage, known as the bulk wash, involves placing prints into the machine where a high-powered motor and propeller forcefully jet streams of isopropyl alcohol (IPA) to rapidly remove the majority of uncured resin. This process is followed by a fine wash stage, utilizing a separate IPA reservoir for a more refined cleaning cycle, ensuring the thorough removal of any residual resin. Upon completion of the wash cycles, a dedicated drying fan circulates air through the chamber to completely dry the models. The core technology of the ProWash S is its mechanical jetting system, which uses a powerful motor and propeller to vigorously direct cleaning solvent onto the parts. This method provides effective agitation and significantly reduces wash times compared to traditional full submersion techniques. Once the solvent is loaded into the reservoirs, the machine operates autonomously, minimizing human interaction with the IPA to only pouring and draining. The device seamlessly integrates with the SprintRay Cloud, facilitating the transfer of job information between devices and automating the workflow from printing to post-processing. An intuitive onboard computer with a touchscreen guides users through various tasks, and calibrated hydrometers indicate when the solvent in each chamber reaches saturation and requires replenishment. Furthermore, the ProWash S offers users the flexibility to create and save custom wash and dry times. A newly incorporated drying fan with a direct-airflow system substantially enhances drying performance, ensuring parts are dry and ready for subsequent curing. The SprintRay ProWash S integrates components sourced from both Thailand and China. Key Thai-manufactured components include the pumps, which facilitate solvent circulation; the propeller, responsible for agitating the solvent to ensure comprehensive cleaning; the motor assembly, which drives the propeller; and the motherboard. The motherboard, serving as the central processing unit, coordinates critical operations such as solvent movement, mechanical agitation, and the drying process. The fan, a Chinese-sourced component, supplies clean air to the chamber, enabling efficient evaporation of volatile solvents and effective drying of the appliance. The motherboard itself is a complex assembly, incorporating 358 electronic components from China, the Netherlands, and Thailand. It is assembled in Thailand using Surface Mount Technology (SMT), with stringent quality control maintained through advanced X-ray and Automated Optical Inspection (AOI) technologies. This motherboard acts as the core intelligence of the ProWash S, orchestrating multiple subsystems to execute the automated two-stage wash and drying functions. It controls the fans, pumps, brushless motors, door magnetic sensors, liquid level sensors, and manages data transmission via the LCD, USB, Wi-Fi, and network ports. Software, developed by SprintRay engineers in the United States, is installed on the motherboard in Thailand, enabling the device's full functionality. Additionally, the screen board, manufactured in Thailand using SMT, serves as the interface between the motherboard and the display, transmitting control signals for visual output and touch functionality. Final assembly of the ProWash S takes place in Thailand, integrating both Thai and Chinese components. This process involves the precise installation and alignment of key elements, including the Thai-origin pump, propeller, motor, motherboard, and sensor board, alongside the China-origin fan. A tightly controlled assembly procedure, utilizing specialized tools and fixtures, ensures seamless integration and consistent precision across all units. To uphold stringent quality requirements, technicians in Thailand undergo extensive training in component handling, calibration, and system testing. The assembly line incorporates multiple quality assurance checkpoints, where each unit is meticulously inspected and tested for functionality and durability, ensuring every ProWash S device meets the highest standards of reliability and performance. 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. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). Based on the rationale derived from New York Rulings N315709 and N330844, and Headquarters Ruling H317645, the country of origin for the SprintRay ProWash S is determined by the components that impart the “essence and function” of the device. In this case, the Thailand-origin pump and motor assemblies are identified as providing the core functionality of washing 3D-printed dental appliances. These components mechanically agitate and circulate solvent for cleaning, and their operations are orchestrated by a Thai-origin motherboard that controls the entire wash and dry cycle. These Thai-origin components are considered integral to the device's operation, as the ProWash S cannot perform its intended function without them. While the China-origin fan is a useful component, it does not define the product’s fundamental character or primary use. Therefore, consistent with the cited rulings, the country of origin of the ProWash S is Thailand, where these essential core components are manufactured and where the final assembly takes place. 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