CLA-2-84:OT:RR:NC:N1:105
Jacquelyn Tai
Gaumann Filtration SDN BHD
No. 57, Jalan I-Park SAC 7
Taman Perindustrian I-Park SAC
Senai 81400
Malaysia
RE: The tariff classification and country of origin of automotive oil filters
Dear Ms. Tai:
In your letter dated August 1, 2025, you requested a tariff classification and country of origin determination
ruling.
The item under consideration is described as an automotive oil filter, which is designed for use in the
lubrication system of internal combustion engines, specifically in passenger vehicles and light-duty trucks.
The filter removes impurities and particulate matter from engine oil to ensure proper lubrication and engine
protection in both gasoline and diesel engines. The outer casing of the filter is made of a corrosion-resistant
steel while the filter media is made from synthetic fiber or cellulose, which is used to trap particulates. The
end caps and center tube are metal or plastic structures that provide support to the filter media. The filter also
has a rubber or metal anti-drain back valve and bypass valve that regulates oil flow and prevents oil leakage.
The oil filter is attached to the engine via a threaded fitting on the base plate, which screws onto the engine’s
oil filter mount. The rubber gasket creates a tight, pressure-resistant seal between the filter and engine block
to prevent oil leaks during operation.
The Chinese components include the paper element assembly, housing assembly, and upper element
assembly. The remaining items are from Malaysia and include the rubber gasket, spring, anti-drain valve,
O-ring, and labels.
The manufacturing process occurs in Malaysia and starts with the injection of the glue and the paper element
assembly. Next, the anti-drain valve is assembled along with the spring assembly. Then the housing assembly
and sealing process is performed before automatic edge cleaning, a leakage test, and placing it in the oven.
After coming out of the oven, the filter is labeled, laser coded with the identifiers, and an anti-rust spray is
added along with the gasket assembly. Finally, the oil filter is inspected and packaged for shipping to the
United States.
The applicable subheading for the oil filters will be 8421.23.0000, 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: Oil or fuel filters for internal combustion engines. The general rate of duty will be 2.5 percent ad
valorem.
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 oil filter, it is our opinion that the manufacturing and assembly process performed
in Malaysia is not considered complex. While numerous steps are needed to assemble the Chinese and
Malaysian components, the core components, including the paper element assembly, housing assembly, and
upper element assembly are not transformed by the simple assembly process in Malaysia. The additional
Malaysian components including the rubber gasket, spring, anti-drain valve, O-ring, and labels are all minor
components in comparison to the Chinese components and only complete the finished article. Therefore, in
our opinion, the country of origin of the oil filter is China, which is where the paper element assembly,
housing assembly, and upper element assembly are constructed.
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 8421.23.0000, 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 of China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 8421.23.0000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8421.23.0000, 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 9903.88.03 in
addition to subheading 8421.23.0000, 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