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 faucet water purifier filter elements
Dear Mr. Wang:
In your letter dated May 7, 2025, you requested a country of origin ruling on faucet water purifier filter
elements. Descriptive literature was provided for our review.
The items under consideration are faucet water purifier filter elements, identified as model numbers
ECF-7008A, ECF-7009A, ECF-7027A, ECF-7042A, EFFF2301TL, ECF-7070C and ECF-F2401A. The
filters are compatible with different models of faucet water purification machines. The filters generally
follow the same structure and packaging steps, with only differences being a slight change in size and
appearance. The products are lead-free and are certified to reduce 97% of chlorine, contaminants, and odor
for better tasting water. The filters are to be discarded and replaced by a consumer approximately every three
months.
The filters are assembled in China using components manufactured in South Korea and China. The filter
element is composed of a Chinese O-ring, upper cover, middle cover, bottom cover, sump, hot melt adhesive,
and a South Korean 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
manually inserting the O-ring into the middle cover/top cover. During this step, 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
this step, the carbon block is pressed vertically without damaging it and it is 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. The ECF-7042A, EFF-F2301TL, ECF-7070C and
ECF-F2401A do not require the third step to be completed and are finished articles after step two. Finally, a
self-inspection is performed to check that the product is free from stains, overflowing glue, cracking, etc.
This is followed by an air tightness test, labeling, 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 faucet water purifier filter elements, 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 faucet water
purifier filter elements, we rely on the origin of the carbon block, which provides the essential function of the
filters. 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 filters and is the item
performing the filtering of the water. Accordingly, the country of origin of the ECF-7008A, ECF-7009A,
ECF-7027A, ECF-7042A, EFFF2301TL, ECF-7070C and ECF-F2401A faucet water purifier filter elements
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