The tariff classification and country of origin of the Lex Aqua closed-loop water treatment system

N360559 April 23, 2026 CLA-2-84:OT:RR:NC:N1:105 CATEGORY: Classification; Origin TARIFF NO.: 8421.21.0000 Ari Penttilä Prorink International AB Valajantie 2 Oulainen 86300 Finland RE: The tariff classification and country of origin of the Lex Aqua closed-loop water treatment system Dear Ms. Penttilä: In your letter dated April 9, 2026, you requested a tariff classification and country of origin determination ruling. The item under consideration is described as the Lex Aqua closed-loop water treatment system, which is an automated solution engineered to optimize ice rink sustainability by effectively recycling melted snow tank water. This advanced system purifies and treats water, removing minerals and impurities to significantly reduce seasonal water consumption, enhance overall ice quality, and lower energy expenditures. The technology capitalizes on the principle that dissolved minerals separate from ice crystals during freezing, and further aids in mineral separation during the resurfacing process, where heavier minerals are deposited into the snow melting pit. Operating autonomously, the Lex Aqua system performs five critical functions: snow melting, ice-making water filtration and replenishment, heating of treated water, dispensing water to the ice resurfacer, and automated system refilling. The system is completely assembled and imported as a fully functional, ready-to-use industrial system, including mechanical structure, piping, filtration units, pumps, valves, sensors, an electrical control cabinet, and control system programming. The filtration process utilizes various media, including washable stainless steel mesh filters for coarse and medium filtration stages, synthetic polyester filter bags for fine filtration, and fiberglass-based media for fine particle removal. The applicable subheading for the Lex Aqua closed-loop water treatment system will be 8421.21.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for liquids: For filtering or purifying water.” The general rate of duty will be free. With respect to the origin, the Lex Aqua closed-loop water treatment system is a globally sourced product, integrating components from numerous countries to create a high-performance system. While the system’s core elements, including the fiberglass filter, polyester filter, stainless steel mesh filters, filter bag, bag filters, filter housing lid, O-rings, electrical control cabinet, flanges, pipes, clamps, wire mesh cable tray, bolts, springs, laser-cut metal components, steel mountings for the heat exchanger, structural steel, and all labor, are completed in Finland, other critical parts originate from across Europe and Asia. Specifically, Italy provides the ultraviolet (UV) disinfection unit, Optix panel, and various fittings. The pump is manufactured in Denmark, and Sweden contributes the plate heat exchanger and HVAC insulation material. The emergency stop, temperature transmitter, and pressure transmitter come from Germany, while Switzerland supplies the conductivity cable, actuator, and ball valves. Poland provides the branch saddle, France the water meter, and Singapore the Compact Logic Enet Motion Controller. The remaining components, including the screw kit, electrical modules, and power supply are sourced from Malaysia. The Lex Aqua industrial water filtration and purification system begins assembly in Finland with the fabrication and welding of a structural steel frame, which serves as the mechanical foundation for all components. Major process elements, including filtration units, pumps, a UV disinfection unit, a heat exchanger, piping, and instrumentation, are then mounted onto the frame. The piping system is subsequently assembled using threaded and mechanically fastened connections, integrating all components into a functional fluid system. Following mechanical integration, an electrical control cabinet is installed, and all wiring, sensors, and control devices are connected. The control system software, including the programmable logic controller (PLC), is developed and programmed in Finland to enable automated operation. The system then undergoes a thorough integration of all mechanical, electrical, and control components to form a complete operational unit. Finally, the entire system is subjected to full functional testing, calibration, and commissioning at the factory in Finland, ensuring it operates correctly before shipment. 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 Lex Aqua closed-loop water treatment system, in our opinion, each of the foreign components are substantially transformed in Finland when integrated into the finished article. While there are key essential components (such as the pump from Denmark or the electrical modules from Malaysia) that are foreign produced, it is not until all of the components are assembled in Finland that the water treatment system assumes the shape, character and use of the finished article. Accordingly, the origin of the Lex Aqua closed-loop water treatment system is Finland. 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 does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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