The country of origin of an air purifier

N359672 April 6, 2026 OT:RR:NC:N1:105 CATEGORY: Origin Jaehoon Lee Sein Customs & Auditing Corp 138, Seoun-ro, Seocho-gu Seoul South Korea RE: The country of origin of an air purifier Dear Mr. Lee: In your letter dated March 12, 2026, on behalf of your client, NUC Electronics Co., Ltd., you requested a country of origin ruling on an air purifier. The item under consideration is described as the Kuvings Air Purifier (item KAP100), which is primarily composed of a HEPA filter, fan, motor, and casing. The product is designed to purify indoor air using a 360-degree circulation purification system while discharging clean air in a spiral flow through a circulator-type grille. The air quality status is indicated by four color levels, allowing intuitive monitoring of indoor air conditions. In automatic mode, the unit adjusts airflow automatically in response to detected pollution levels. The unit is capable of purifying air within an area of up to 70 square meters. This air purifier has 9 distinct components, drawing materials from both Korea and China to create the final unit. Key modules, such as the display and motor, incorporate parts from both nations, with Korean contributions including window displays, housing mount brackets, and support for the display module, while China supplies diffuser sheets, shade brackets, motor covers, and main motor components. The fan blade assembly is entirely from China, and the air duct bracket integrates Korean elements like buttons and brackets with numerous Chinese parts including adapter boxes, printed circuit boards, and various switches. Similarly, the upper cover and sensor assembly feature a mix of Korean and Chinese sourced materials, with the HEPA filter being a Korean-made air filter. The lower cover and base also combine Korean and Chinese parts, from LEDs and brackets to printed circuit board assemblies (PCBA) and springs, with additional parts like screws and user guides originating from Korea, and power cord assemblies and remote controls from China. The manufacturing of the air purifier is conducted in Korea, beginning with the procurement of all Chinese-sourced components and the Korean-produced HEPA filter. The HEPA filter itself undergoes domestic fabrication through laminating, pleating, and mini-pleat processes. Following this, injection molding, parts fabrication, and the assembly of the air purifier’s aerodynamic sections and housing take place. Core functional elements, including the HEPA filter, aerodynamic housing, duct structures, control/display assemblies, and fan blade assembly are manufactured and integrated in Korea. These parts are secured through screwing, gluing, or snapping. Components of Chinese origin, such as the motor and printed circuit boards, are then specifically screwed into place. The Korean manufacturing operations encompass multiple stages including plastic injection-molding, HEPA filter fabrication, sub-assembly, final assembly, and performance testing. In total, the process takes approximately 62 minutes per unit and requires over 47 production workers and supervisors. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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, critical manufacturing operations, including the production of injection-molded housing, aerodynamic air-duct structures, the HEPA filter module, and various mechanical and display sub-assemblies, are performed in Korea. These operations, which also encompass final assembly and comprehensive performance testing, are where non-originating Chinese components are integrated with Korean-manufactured parts. It is in Korea that the air purifier first acquires its definitive structure, performance characteristics, and commercial identity as a complete, marketable household appliance. Additionally, in our view, the manufacturing activities undertaken in Korea extend beyond simple assembly, representing the core production that establishes the air purifier’s fundamental structure and aerodynamic characteristics. Accordingly, the country of origin of the Kuvings Air Purifier (item KAP100) will be Korea. 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 P. Forkan Director National Commodity Specialist Division