The country of origin of dishwashers

N357813 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 A3 Dishwashers (models WQP12-67E1 and WQP12-6708E). These built-in commercial 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 five primary subassemblies: the inner tub (the main washing chamber), the base tray (collects water and supports damage and pump system), the upper and lower baskets (for secure dish placement), the water cup (regulates water intake and distribution between washing), and the air breather (which regulates air pressure in the water line). Manufacturing is carried out in Egypt using components sourced from Egypt and China. The Egyptian components include the outer door, inner door, inner tub top plate, inner tub middle plate, inner tub base plate, sealing frame, stiffener assembly, right and left stiffener, base tray, water cup, diversion block, air breather upper and lower plates, junction box cover, base tray cover, right and left side panels, top and lower spray arms, cutlery assembly, lower, upper and cutlery basket, activity row, upper sprayer assembly, connectors, snap ring, pipes, upper sprayer, and bottle wash arm. The Chinese components include the control panel cover, control panel, handle, stainless steel sheet, dispenser, hinges, brackets, absorbent cotton, rail assembly, tub damping, door lock, seals, heating tube assembly, galvanized steel sheet, hinge holders, filter, modified plastic particles, check valves, sump cover, induction and drain pumps, inlet valve, hooks, pressure switch, polypropylene, flowmeter, printed circuit board (PCB) box and covers, float seat, float, pipes, main control panel, wire harness, adjust feet, worm wheel, poles, gear box, screws, adjustable baseboard, springs, rope, wire, cutlery wheel, plastic powder, and basket wheel. The first of five stages in the process is the injection molding, which produces key plastic components such as the water cup, base tray, air breather, base tray cover, cutlery basket, cutlery tray, and spray arm. Polypropylene and color masterbatch are dried, mixed, injected into molds, cooled, trimmed, and inspected before mass production proceeds. The second stage, metal stamping, begins with steel coil sheets being cut, drawn, punched, flanged, and shaped to form the outer door and side panels, followed by the application and curing of damping material. Stainless steel plates undergo similar processes to create the inner door, tub middle plate, and back board. The sealing frame is shaped using a forming machine. Additionally, galvanized steel from a third-party vendor is precision stamped to produce components such as stiffeners, the upper sprayer, junction box, and junction box cover assembly, all of which undergo quality inspection. The third stage, subassembly production, involves the creation of several key components. The inner tub subassembly is formed through bending, riveting, welding, sealing, and curing, with subsequent addition of stiffeners, sealing frames, hinge supports, and guide rails. Upper and lower baskets undergo hydroforming, spot-welding, and powder-coating, followed by the integration of rollers, spray arms, and a cutlery rack. The base tray subassembly is assembled by connecting wires from the main control board, attaching the wiring harness, and securing the chassis with screws, with most remaining parts fastened using clips and screws. The cutlery subassembly, consisting of the basket body, cover, handle, and other functional parts, is produced via injection molding, with components then assembled using snap fasteners. The air breather subassembly involves assembling components such as the flow restrictor, check valve, and flow meter, followed by hot melt welding to seal the unit. Finally, the water cup subassembly is completed by installing the check valve, inlet pipe, and drainpipe. The fourth stage, final assembly, involves installing the respirator, drainpipe, wiring harnesses, spray arms, inner door, decorative panel, and water inlet components. Water inlet performance is tested, and leak checks are conducted. Finally, the structural enclosure, comprising the 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 A3 Dishwashers (models WQP12-67E1 and WQP12-6708E), it is our opinion that the Chinese components undergo a substantial transformation in Egypt. The individual items are changed into new articles with a different name, character, and use once they are combined with the complex Egyptian manufacturing and components. Therefore, the country of origin of the A3 Dishwashers will be Egypt, which is where the substantial assembly and manufacturing processing is performed. 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