OT:RR:NC:N1:105
Richard O'Neill
Neville Peterson LLP
701 Fifth Avenue, Suite 4200-3159
Seattle, WA 98104
RE: The country of origin of water purification and filtration cartridges
Dear Mr. O'Neill:
In your letter dated July 1, 2025, on behalf of your client, Grayl Inc., you requested a country of origin ruling
on water purification and filtration cartridges.
The items under consideration are described as replacement water purification and filtration cartridges for the
GeoPress and UltraPress filtration systems. Each cartridge houses a proprietary nonwoven filter media, which
enables the core water purification functionality by removing submicron biological, chemical, and particulate
contaminants. The filter cartridges are cylindrical replacement filter units inserted by the user into a rigid
outer bottle to create a complete press-style filtration system. When inserted into their corresponding bottle
and pressed down into untreated water, 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 water produced within only a few seconds of operation. Both the GeoPress and UltraPress bottle
products are designed for outdoor, emergency, and travel use, allowing users to produce safe, potable water
from virtually any freshwater source (e.g., rivers, lakes, taps, wells) without the use of electricity or
chemicals.
The GeoPress (24 oz. capacity) is designed for higher volume filtration and more rugged environments. The
GeoPress accommodates a longer-lasting purifier cartridge, up to 350 uses or 65 gallons. The GeoPress
weighs approximately 15.9 ounces and features a thicker, more impact-resistant shell with a thermoplastic
rubber base to endure field use. The GeoPress includes a more robust top cap and lockable spout suitable for
high-mobility use. The UltraPress (16.9 oz. capacity) is more compact and lightweight, suitable for individual
use during hiking or travel. The UltraPress cartridge is rated for 300 uses or 40 gallons. The UltraPress
weighs 12.5 ounces, has a slimmer profile, and fits more easily in backpack bottle holders. The UltraPress
features a more compact, lower-profile lid.
To operate, the user fills the outer bottle with untreated water, inserts the inner press, and applies downward
pressure. As the inner press moves through the water, it forces liquid through the purifier cartridge, removing
viruses, bacteria, protozoa, and a wide range of particulates, chemicals, heavy metals, and taste/odor
compounds.
The non-woven electro-adsorptive filter media 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.
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 origin of the replacement water purification and filtration cartridges, the final assembly
process in China predominantly involves molding a plastic housing, gluing, 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 replacement water purification and filtration cartridges, we rely on the origin of the
non-woven electro-adsorptive filter media, which provides the essential function of the filter. It is the filter
media from the United States which requires considerable technical experience and customized equipment to
produce and is the item performing the filtering of the water. Accordingly, the country of origin of the water
purification and filtration cartridges for the GeoPress and UltraPress filtration systems will be the United
States, which is where the non-woven electro-adsorptive filter media 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,
(for)
James Forkan
Acting Director
National Commodity Specialist Division