CLA-2-84:OT:RR:NC:N1:105
Chris Wang
Qingdao Ecopure Filter Co., Ltd.
No.13, Yishengbai Road, Jimo
Qingdao 266201
China
RE: The tariff classification and country of origin of under-the-sink water filtration systems.
Dear Mr. Wang:
In your letter dated March 20, 2025, you requested a tariff classification and country of origin ruling.
Descriptive literature was provided for our review.
The items under consideration are described as Single-Stage Carbon Block Under Sink Water Filtration
Systems (model numbers WD-10UAW, WD-15UA, WD-10UY, WD-15UAW, WD-17UA, WD-17UAW,
WD-UL12B, WD-UL12A, WD-FUL12, and WD-UA-5Y), which provide clean water directly from a faucet.
The products generally follow the same structure and packaging steps, with the only differences being in
specifications and dimensions. The devices connect to the cold-water line leading to the sink. The filters are
designed to reduce chlorine, contaminants, and odor for better tasting water. The filters are to be discarded
and replaced by a consumer approximately every twelve months. In addition to the main filter element, there
are also several other components that help the user to install the unit, which are included in the connector kit
and accessory pack. All of the items are packaged together into one retail package. The package contains a
stainless-steel water supply pipe, timer, nuts, Teflon tape, a spring, screw, O-rings, ¼ craw, connector switch
cover, connector switch, fixed ring, joint upper cover, joint cup holder, stent, and T-joint.
The Explanatory Notes to the Harmonized Tariff System provide guidance in the interpretation of the
Harmonized Commodity Description and Coding System at the international level. Explanatory Note X to
GRI 3 provides that the term “goods put up in sets for retail sale” mean goods that: (a) consist of at least two
different articles which are prima facie, classifiable in different headings; (b) consist of articles put up
together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for
sale directly to users without repacking. It is the opinion of this office that the items packaged together do
represent a set in accordance with Explanatory Note X. In accordance, in part, with GRI 3(b) “goods put up
in sets for retail sale, which cannot be classified by reference to GRI 3(a), shall be classified as if they
consisted of the material or component which gives them their essential character.” Explanatory Note VIII to
GRI 3(b) states that the factor which determines essential character will vary between different kinds of
goods. It may, for example, be determined by the nature of the material or component, its bulk, quantity,
weight or value, or by the role of the constituent material in relation to the goods. In our opinion, the essential
character of the Single-Stage Carbon Block Under Sink Water Filtration Systems is imparted by the carbon
block water filters.
As you suggest in your letter, the applicable subheading for the Single-Stage Carbon Block Under Sink
Water Filtration Systems (model numbers WD-10UAW, WD-15UA, WD-10UY, WD-15UAW, WD-17UA,
WD-17UAW, WD-UL12B, WD-UL12A, WD-FUL12, and WD-UA-5Y) will be subheading 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 is
free.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS
and the accompanying duty rates are provided at https://hts.usitc.gov/current.
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 country of origin of the water filtration systems, the systems are assembled in China using
components manufactured in South Korea and China.The filtration systems consist of a filter element, a
connector and an accessory pack. The filter element is composed of a Chinese O-ring, upper cover, middle
cover, bottom cover, sump, transparent protective film, and a South Korean carbon block. The kit contains a
Chinese stainless-steel water supply pipe, timer, nuts, and Teflon tape. The connector contains a Chinese
spring, screw, O-rings, ¼ craw, connector switch cover, connector switch, fixed ring, joint upper cover, joint
cup holder, stent, and T-joint.
The carbon block removes contaminants from water through a process called “adsorption.” Adsorption is a
process in which contaminants are attracted to the surface of the carbon granules and become trapped in the
small pores of the filtration media. The carbon block requires substantial processing to create and accounts
for the most substantial costs of the overall filters.
The entire production and packaging process includes twelve steps and is completed by fourteen workers.
The filter element assembly consists of five steps and is completed by six workers. The first step in the filter
assembly process involves one worker manually inserting the O-ring into the middle cover/top cover. During
the process, visual inspection is conducted to ensure there are no scratches, stains, or color differences. The
next step involves one worker operating glue dispensing equipment to glue the middle cover, carbon rod, and
bottom cover together. During the process, the carbon block is pressed vertically without damage and evenly
bonded. The third step involves one worker operating a rotary welding machine to weld and bond the upper
cover, glue-dipping carbon rod, and sump to form a complete filter element. Next is the air tightness test
where a worker installs the assembled, finished filter element on the air tightness testing equipment and
performs a visual self-inspection. Finally, a worker will combine the filter with the additional accessory kit
and connectors and place them in their final retail packaging.
In regard to the country of origin of the Single-Stage Carbon Block Under Sink Water Filtration Systems
(model numbers WD-10UAW, WD-15UA, WD-10UY, WD-15UAW, WD-17UA, WD-17UAW,
WD-UL12B, WD-UL12A, WD-FUL12, and WD-UA-5Y), it is our opinion that the assembly process
performed in China is not considered complex and does not constitute a substantial transformation. While
there are many different individual components, each component only performs a small function for the
overall system. Additionally, the construction of the filter itself predominantly involves gluing, welding, and
pressing various components into place. The combining of all of the parts in China does not create a new and
different article of commerce with a name, character, and use distinct from the individual components.
Therefore, to determine the country of origin of the Single-Stage Carbon Block Under Sink Water Filtration
Systems, we look to the origin of the carbon block, which provides the essential function of the entire system.
It is the carbon block from South Korea which requires considerable technical expertise and customized
equipment to produce. It is also the most expensive portion of the system and is the item performing the
filtering of the water. Accordingly, the country of origin of the Single-Stage Carbon Block Under Sink Water
Filtration Systems (model numbers WD-10UAW, WD-15UA, WD-10UY, WD-15UAW, WD-17UA,
WD-17UAW, WD-UL12B, WD-UL12A, WD-FUL12, and WD-UA-5Y) will be South Korea, which is
where the carbon block is manufactured.
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division