OT:RR:NC:N1:105
Chris Wang
Qingdao Ecopure Filter Co., Ltd.
No.13, Yishengbai Road, Jimo Qingdao 266201
China
RE: The country of origin of household water filters
Dear Mr. Wang:
In your letter dated April 27, 2025, you requested a country of origin ruling. Descriptive literature was
provided for our review.
The items under consideration are described as household water filters, identified as model numbers
EWF-8056A and EFF-6035A. The lead-free filters are long plastic filters that contain a carbon block for
reducing 97% of chlorine, contaminants, and odor for better tasting water. The products are attached to water
pipes on both ends of the filter. They are suitable for a wide range of scenarios and can be used in such places
as recreational vehicles, under kitchen sinks, etc. The filters generally follow the same structure and
packaging steps, with the only difference being a slight change in size of the interfaces at both ends of the
plastic shell. The EFF-6035A interface is ¼ inch while the EWF-8056A is ¾ inch.
The filters are assembled in China using components manufactured in Sri Lanka and China. The filter
element is composed of a Chinese O-ring, upper cover, middle cover, bottom cover, sump, non-woven
fabrics, claw interfaces, and a Sri Lankan carbon block. 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 largest cost of the overall filters.
The entire production and packaging process includes six steps and is completed by six workers. It is divided
into two parts: filter element assembly and product packaging. The filter element assembly consists of three
steps and is completed by three workers.
The first step in the filter assembly process involves one worker placing the non-woven fabric on the upper
cover and the cup base, then bonds them respectively and checks for no damage or dirt. The next step
involves one worker loading the activated carbon purchased from Sri Lanka into the cup holder according to
the weight requirement. The third step involves one worker operating a rotary welding machine to weld and
bond the upper cover and the filled cup seat to form a complete filter element. Finally, a self-inspection is
performed to check that the product is free from stains, overflowing glue, cracking, etc. This is followed by
boxing, sealing, and final packaging.
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 household water filters, it is our opinion that the assembly process
performed in China is not complex and does not constitute a substantial transformation. The process
predominantly involves gluing, welding, and pressing various components into place. The combining of these
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 household water
filters, we rely on the origin of the carbon block, which provides the essential function of the filters. It is the
carbon block from Sri Lanka which requires considerable technical expertise and customized equipment to
produce. It is also the most expensive portion of the filters and is the item performing the filtering of the
water. Accordingly, the country of origin of the EWF-8056A and EFF-6035A household water filters will be
Sri Lanka, 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