CLA-2-84:OT:RR:NC:N1:105
Enrique Perez
Plasticos Promex DBA Quantum Plastics
1220 Barranca, Building 4C
El Paso, TX 79935
RE: The tariff classification and origin of a purifier bottle from China
Dear Mr. Perez:
In your letter dated June 30, 2025, you requested a tariff classification and country of origin ruling for a
purifier bottle. Descriptive literature was provided for our review.
The item under consideration is described as the 24 oz. GeoPress Ti Purifier Bottle. The device is made from
CP4 Grade 1 Titanium and is designed to filter and purify water at any freshwater source (lakes, streams,
rivers, etc.). The bottle provides fresh drinking and cooking water in a camping or outdoor environment
without the use of electricity. The advanced filter cartridge houses a proprietary nonwoven filter media,
which enables the core water purification functionality by removing submicron biological, chemical, and
particulate contaminants. The replacement cylindrical filter cartridge is inserted by the user into the rigid
titanium inner before being inserted into the titanium outer. The addition of the top cap completes the
press-style filtration system. In operation, the user scoops water from the source with the titanium outer, then
adds the titanium inner (that includes the top cap and filter cartridge) before pressing down into the untreated
water. The water is forced through the cartridge’s internal filter media, which in turn captures viruses,
bacteria, protozoa, particulates, chemicals, and heavy metals. The result is purified drinking or cooking water
produced within only a few seconds of operation.
The applicable subheading for the 24 oz. GeoPress Ti Purifier Bottle 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.
In your letter, you also requested a determination on the country of origin for the purpose of applying current
trade remedies. The 24 oz. GeoPress Ti Purifier is assembled in Mexico from components made in China,
Mexico, and the United States. The Chinese components include the titanium inner, silicone titanium inner
body collar, titanium outer, titanium cook lid, filter cartridge assembly (which includes a Chinese silicone
seal, Chinese silicone O-ring, and a U.S.-origin filter media), silicone one-way valve, silicone gasket, screws,
nut, and packaging. The Mexican components include the plastic lid assembly that includes the lid
polypropylene (PP) and thermoplastic elastomer (TPE) overmold, strap PP and TPE overmold, and the cap
core PP and TPE overmold.
The manufacturing of the cartridge starts with the creation of the non-woven electro-adsorptive filter media,
which is manufactured in the United States and requires 60 skilled workers and dedicated industrial
equipment to produce. The process begins with melt-blown fiber extrusion to create high-aspect-ratio
alumina/glass continuous fibers. Then, slurry blending occurs with cellulose pulp and activated carbon fibers
in a precise weight ratio. Next, the web formation is created on a flat wire fourdrinier paper machine to
produce a highly uniform composite followed by the lamination of multiple fiber layers under precise heat,
tension, and time controls. The surface is then treated with proprietary compounds to increase electropositive
charge density before cutting and quality control testing for flow rate, microbial retention, and contaminant
removal. Finally, bio-testing occurs to ensure efficacy in the removal of biological pathogens, inorganics, and
heavy metals.
The manufacturing process then shifts to China where the U.S.-origin filter media is pleated into cylindrical
form, hot-sealed into pleat packs, and inserted into Chinese produced polypropylene plastic end caps, which
are then glued and cured. Two silicone O-rings are then affixed to complete the cartridge.
The assembly process in Mexico starts with obtaining all of the Chinese, U.S. and Mexican components. The
plastic lid assembly, that includes the PP and TPE overmold, strap PP and TPE overmold, and the cap core
PP and TPE overmold, are all manufactured in Mexico before starting the assembly process. Once all items
are obtained, workers assemble the top cap and combine the Chinese produced titanium inner with the
titanium outer and silicone titanium inner body collar. Then the top cap is screwed into place. The filter
cartridge assembly is then screwed onto the bottom of the titanium inner after the silicone one-way valve is
placed. After the assembly is complete, the item is inspected and packaged for shipment to the United States.
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).
In regard to the country of origin for the purpose of applying current trade remedies, several of the core
components including the titanium inner, titanium outer, and silicone one-way valve are all manufactured in
China prior to shipping to Mexico for final assembly. The replacement filter cartridge is assembled in China
but contains the proprietary U.S.-origin non-woven electro-adsorptive filter media. The assembly process in
Mexico, involves taking the Chinese components and U.S. filter cartridge and performing simple actions such
as screwing and pressing items into place. The addition of the Mexican lid components adds to the finished
nature of the article but does not change the primary function of the filtering bottle. In order to perform the
filtering function, the user must have the filtration cartridge, the titanium inner and the titanium outer.
Missing any of these core components would not allow the item to perform the filtering function.
Therefore, it is our view that the Chinese components are not substantially transformed into a different article
of commerce with a new character and use. The components, while disassembled and requiring a few
additional items, are specifically designed to be a press-style filtration system and cannot be used for any
other purpose. The titanium components contain the highest cost of the overall filtration system and also
contains the shape and size of the finished product. As such, the country of origin of the 24 oz. GeoPress Ti
Purifier will be China for the purpose of applying current trade remedies, which is where the titanium
components are manufactured prior to simple assembly.
In regards to marking, Section 304, Tariff Act of 1930, as amended (19 U.S.C. § 1304), provides that, unless
excepted, every article of foreign origin (or its container) 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. Part 134 of the U.S. Customs and Border Protection (CBP) Regulations (19
C.F.R. Part 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. § 1304.
The “country of origin” is defined in 19 CFR 134.1(b) 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 this part; however, for a good of a USMCA country, the marking rules set forth
in part 102 of this chapter (hereinafter referred to as the part 102 Rules) will determine the country of origin.”
Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other
USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in
§§ 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to
goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining the
country of origin of a good for marking purposes, with the exception of textile goods which are subject to the
provisions of 19 C.F.R. § 102.21. See 19 C.F.R. § 102.11.
Applied in sequential order, 19 CFR Part 102.11(a) provides that the country of origin of a good is the
country in which:
(1) The good is wholly obtained or produced;
(2) The good is produced exclusively from domestic materials; or
(3) Each foreign material incorporated in that good undergoes an applicable change in tariff classification set
out in Part 102.20 and satisfies any other applicable requirements of that section, and all other applicable
requirements of these rules are satisfied.
The 24 oz. GeoPress Ti Purifier Bottle is neither “wholly obtained or produced” nor “produced exclusively
from domestic materials.” Therefore, paragraphs (a)(1) and (a)(2) cannot be used to determine the country of
origin of the 24 oz. GeoPress Ti Purifier Bottle, and paragraph (a)(3) must be applied next to determine the
origin of the finished article. The 24 oz. GeoPress Ti Purifier Bottle is classified under subheading 8421.21,
HTSUS. The tariff shift requirement in Part 102.20 for subheading 8421.21 states:
A change to subheading 8421.11 through 8421.39 from any other subheading, including another subheading
within that group.
Since the 24 oz. GeoPress Ti Purifier Bottle is made of Chinese component parts that are not considered
complete filters of 8421.21 and come from subheadings outside of 8421.11 through 8421.39, and all undergo
processing in Mexico to turn it into an article of heading 8421, the tariff shift requirement of section
102.11(a)(3) is met. Accordingly, the country of origin of the 24 oz. GeoPress Ti Purifier Bottle for marking
purposes is Mexico.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition
to subheading 8421.21.0000, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading
8421.21.0000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8421.21.0000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading 9903.88.01 in
addition to subheading 8421.21.0000, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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/.
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,
(for)
James Forkan
Acting Director
National Commodity Specialist Division