The country of origin of an air purifier

N359251 March 17, 2026 OT:RR:NC:N1:105 CATEGORY: Origin Donghyun Seo Coway Co., Ltd 136-23, Yugumagoksa-ro, Yugu-eup Gongju-si, Chungcheongnam-do South Korea RE: The country of origin of an air purifier Dear Mr. Seo: In your letter dated February 27, 2026, you requested a country of origin ruling on an air purifier. Descriptive literature was provided for our review. This request is similar to New York Ruling N359250 with a slight change in product sourcing and manufacturing. The item under consideration is described as the Columbia air purifier, which is a smart home appliance engineered for indoor air quality management. This device employs a comprehensive filtration system designed to capture 99.97% of airborne particles. Its multi-layered approach begins with a washable pre-filter to trap larger debris such as dust, hair, and pet fur. This is followed by an activated carbon filter, which effectively neutralizes volatile organic compounds (VOCs) and common household odors from sources like pets, smoke, and cooking. A true HEPA filter then captures 99.97% of microscopic allergens, including pollen, mold spores, and pet dander. The Columbia model also features intelligent air quality monitoring with automatic fan speed adjustments, an energy-efficient eco mode, and a compact design, making it an ideal solution for maintaining a healthy and comfortable residential environment. The air purifier is assembled in Thailand with components sourced from Thailand, South Korea, Japan, and China. The sensor particle is produced in Japan while the composite filter, motor and blade assembly, cover motor guide, magnetic cistern cover, printed board assembly (PBA)-power, PBA-key assembly, and PBA-main are sourced from China. The insert fan assembly, sensor select bar and PBA-WiFi assembly are all from South Korea. The remaining parts are all sourced from Thailand including the guide fan, fan, and all of the additional nuts, bolts, washers, packaging, and plastic components necessary to complete the finished article. The manufacturing process for the air purifier components begins in Thailand, where plastic resin is fed into injection molding equipment to produce various semi-finished parts essential for assembly, such as the filter assembly, covers, lens key, and lens light sensor. Concurrently, in China, the filter assembly is meticulously constructed by filling a deodorizing filter case with activated carbon. A hexagonal mesh is then thermally bonded to this assembly using a heat/cold press system. The deodorizing filter is subsequently integrated with a HEPA filter pack within a paper frame, secured with double-sided tape and hot-melt adhesive. A nonwoven handle is attached, and the paper frame’s perimeter is reinforced and bonded with polyurethane (PU) foam. The final stages involve the application of labels, finishing with filament tape, and packaging of the completed assembly. Following the manufacturing of injection-molded plastic resin components, the air purifier undergoes a comprehensive assembly process, segmented into distinct sub-assembly and main assembly stages. In the sub-assembly phase, various semi-finished components are sequentially integrated. This includes mounting the PBA-power onto the cover-power lower and establishing electrical connections with harness-power connectors. Concurrently, lens-key, lens-pollution, and PBA-key assembly components are installed onto the top cover, with electrical connections completed via harness-key PBA connectors. Further sub-assembly involves inserting deco-filter guide components into the guide-filter, attaching the sensor-select bar, and securing a magnet within the deco-front cover. The cover-front lower is then fitted with the deco-front to complete the front cover assembly. All these steps utilize powered screwdrivers for secure fastening. The main assembly stage focuses on integrating the core functional elements: the motor is seated onto the guide-fan, its wires are routed, and the cover-motor guide is installed to secure it. The motor shaft is precisely aligned with the fan, secured with a washer spring and hex nut, and attached using a powered tool. Throughout both stages, injection-molded parts and sub-assembly units are conveyed to designated stations, where components are aligned and mechanically secured with screws using powered screwdrivers. Next, the finished air purifier undergoes four functional tests, labeling, and final packaging before being stacked on a pallet. 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). Regarding the origin of the air purifier, in our opinion, the air purifier’s components, including sensors, filters, electronic controls, and air circulation mechanisms, undergo a transformative assembly process in Thailand. While initially standalone, these elements are integrated to form a new electronic device with distinct technological properties and a complex functional structure, thereby losing their individual physical or mechanical characteristics. Furthermore, components sourced from China, South Korea, and Japan are combined with Thailand-origin components to create new sub-assemblies within Thailand, which are then utilized in the final product’s manufacturing. This intricate assembly process in Thailand is deemed to result in a change in the name, character, and use of the raw materials. Consequently, the country of origin of the finished Columbia Air Purifier is Thailand. 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) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division