OT:RR:NC:N1:102
James Amyx
Sandler, Travis & Rosenberg, P.A.
5835 Waterford District Drive, Suite 200
Miami, FL 33126
RE: The country of origin of a compressor
Dear Mr. Amyx:
In your letter dated October 31, 2025, on behalf of your client, Universal Air Conditioner, LLC., you
requested a country of origin ruling on a compressor to apply current trade remedies and for marking
purposes.
The product at issue is a compressor, SKU 68510505. The compressor is designed to be installed in a motor
vehicle and connected to the belt system of the engine. Once powered, the pistons of the compressor’s
swashplate subassembly transfer rotational power within the planetary disc subassembly, which moves back
and forth. The resulting motion pressurizes and displaces gas used in the air conditioning system.
With respect to origin, the final assembly of the compressor occurs in Taiwan using components primarily
from Taiwan and China. Prior to the final assembly, a cylinder block, rear and front covers, a rear cover plate
and certain subassemblies are produced in Taiwan.
To produce the cylinder block, rear and front covers, and the rear cover plate, raw metal from Taiwan is
melted in a furnace and subsequently pressed into a mold. Afterwards, the mold is deburred and shot blasted.
Next, the covers, rear cover plate and cylinder block are machined. During the machining, the threaded holes
and mounting grooves are formed using boring and facing operations.
The production of the swashplate subassembly begins by sourcing a swashplate casting from China. In
Taiwan, the surfaces of the plate and shaft are turned, and holes are incorporated into the plate. The inclined
surfaces are milled, and the working surfaces are ground. Afterwards, the swashplate is heat treated and
anodized. To form the swashplate seat, raw material from China is forged, heat treated, and machined
roughly and precisely to create the oil channels and mounting holes. The seat is then quenched and tempered.
To form the main shaft and shaft arm, raw material is sourced from China and forged. Afterwards, the
forgings are quenched and tempered, followed by the quenching and tempering of the outer diameter and
ends. The ends are drilled, machined, hardened and coated.
To form the pulley, the outer surfaces of a forging blank from China are turned. The belt grooves are
machined, a central hole is drilled, and all edges are chamfered. The burrs on the edges are removed. The
pulley is then hardened and coated.
To form the coil, copper wire from China is connected to electrical terminals using a soldering process.
Subsequently, the coil is inserted into a housing and encapsulated with epoxy.
During the final assembly, a shim is inserted into a swashplate seat and swashplate and tightened using a
machine. Then, a return spring is installed into the bottom of a main shaft arm. Afterwards, a connecting
block and two shaft pins are inserted and pressed in place. Next, a pin, a retaining ring and sleeve are
manually inserted and pressed together. The process continues by threading a valve gasket and pressing it
into a check valve, which is then screwed onto a rear cover. Bearings are then pressed in position, and a seat
ring and washers are inserted into the cylinder block. Then, a main shaft and piston-hemispherical shoe are
installed onto the swash plate, which is subsequently inserted into the cylinder block. Once lubricant is
applied, dowel pins, a gasket, a bearing and a front cover are installed. Next, a shaft seal and ring are pressed
onto the shaft end of the compressor assembly, and a rear valve subassembly is then completed and installed
into the cylinder block. Subsequently, a rear cover is bolted in place, a valve plate assembly is installed and
oil is filled. Afterwards, a coil subassembly and a pulley are pressed onto the front cover, and a wire clamp is
screwed in place, which is followed by the fastening of a drive disk onto the pulley hub. The f inished
compressor is packaged ready for shipment.
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).
Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless
excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous
place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a
manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin
of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be
able to know by an inspection of the marking on the imported goods the country of which the goods is the
product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may,
by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should
influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940).
Part 134 of the U.S. Customs and Border Protection (CBP) Regulations (19 CFR 134) implements the
country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP
Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or
growth of any article of foreign origin entering the United States. Further work or material added to an article
in another country must effect a substantial transformation in order to render such other country the “country
of origin” within the meaning of the marking laws and regulations.
CBP has held that whether an assembly process is sufficiently complex to rise to the level of a substantial
transformation is determined upon consideration of all the operations that occur within that country. Here,
forged components are machined and finished in Taiwan, including the swashplate and planetary disc
subassemblies, which are then combined with other components such as a Taiwanese manufactured cylinder
block and rear head to form a compressor in Taiwan. When considering the totality of the circumstances, this
office finds that the processes that occur in Taiwan, taken as a whole, are sufficiently complex and
meaningful as to result in a substantial transformation, such that the non-originating components lose their
individual identities and become an integral part of a new article, possessing a new name, character and use.
Based on the processes described in the submission, we find the country of origin of the compressor is
Taiwan.
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 Sandra Martinez at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division