The country of origin of dishwashers

N357811 January 22, 2026 OT:RR:NC:N1:105 CATEGORY: Origin Chengyue Liu Midea (Egypt) Kitchen & Water Heater Appliance Co. Ltd North-West Gulf of Suez Economic Zone Ain Sokhna Suez Egypt RE: The country of origin of dishwashers Dear Mr. Liu: In your letter dated January 14, 2026, you requested a country of origin ruling on dishwashers. Descriptive literature was provided for our review. The items under consideration are described as High Polaris Dishwashers (models WQP12-5901K-US, WQP12-59M6-US, WQP12-5909V-US, WQP12-5909W-US, and WQP12-59E1-US). These built-in household dishwashers are designed to fit under kitchen counters and clean tableware using hot water, detergent, and rotating spray arms. Each unit is sold as a complete packaged system and incorporates four primary subassemblies: the inner tub (the main washing chamber), the chassis (structural framework for mechanical and electrical components), the upper and lower baskets (for secure dish placement), and the air breather (which regulates air pressure in the water line). In Egypt, manufacturing is executed by integrating locally sourced elements with parts sourced from China. The Egyptian-origin components include the connecting board, lower basket, steel wire, cutlery basket, lampstand, float seat, float shrapnel, floater, back board, tub middle plate, stiffeners, sealing frame, angle plate, upper back support, base tray cover, lower sprayer assembly, lower sprayer shaft, air breather, snap ring, connector, middle sprayer pipe, upper sprayer, and the upper basket. Conversely, the Chinese-origin components include absorbent cotton, screws, galvanized sheet, gaskets, brackets, plastic powder, modified plastic particles, clamps, caps, pipes, control panel, stickers, display printed circuit board (PCB), door lock, filter handle, handle box, induction pump, valves, junction box, main control panel, wire harness, switches, pins, sealing rings, plastic sleeves, rail support, rope pulley, valve covers, wheel, and waterproof silicone pad. The first of five stages in the process includes the injection molding, which produces key plastic components such as sprayer parts, float assemblies, the cutlery basket, connectors, and support structures. Polypropylene and color masterbatch are dried, mixed, injected into molds, cooled, trimmed, and inspected before mass production proceeds. The second stage involves metal stamping. Steel coil sheets are used to form the outer door and side panels through cutting, drawing, punching, flanging, and shaping, after which damping material is applied and cured. Stainless steel plates undergo similar processes to create the inner door, tub middle plate, and back board, while the sealing frame is shaped using a forming machine. Additional components such as stiffeners, connecting boards, and angle plates are produced by a third-party vendor through precision stamping and are inspected for quality. The third stage is subassembly production. The inner tub subassembly is created through bending, riveting, welding, sealing, and curing, with stiffeners, sealing frames, hinge supports, and guide rails added during assembly. The upper and lower baskets are hydroformed, spot-welded, powder-coated, and fitted with rollers, spray arms, and a cutlery rack. The chassis subassembly is built by installing the heating tube, control board, sensors, drain pump, thermostat, inlet valve, wiring harnesses, guide wheels, and other functional elements. The fourth stage is final assembly. Workers install the respirator, drainpipe, wiring harnesses, spray arms, inner door, decorative panel, and water inlet components. They also test the water inlet for proper performance and check for leaks. The structural enclosure, including side panels, baseboard, and outer door, is attached and secured to complete the unit. The fifth and final stage consists of testing, inspection, and packaging. Each dishwasher undergoes electrical safety testing, functional checks, and detailed visual inspection to confirm proper alignment, sealing, labeling, and appearance. After passing all evaluations, each unit is packaged with foam inserts and corner guards before being sealed in a protective carton. 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 High Polaris Dishwashers (models WQP12-5901K-US, WQP12-59M6-US, WQP12-5909V-US, WQP12-5909W-US, and WQP12-59E1-US), it is our opinion that the Chinese components undergo a substantial transformation in Egypt. The integration of various components through Egyptian manufacturing results in a substantial transformation, creating a new article of commerce with a distinct name, character, and use. Consequently, the country of origin for High Polaris Dishwashers is Egypt, the site of the primary manufacturing and assembly operations. 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division