OT:RR:NC:N4:410
Xiaolei Liu
Midea Kitchen and Water Heater Manufacturing (Thailand) Co., Ltd.
No. 386/56 Moo 2, Khao Khansong Sub-District, Sriracha District
Chonburi Province
Thailand
RE: The country of origin of water dispensers from Thailand
Dear Mr. Liu:
In your letter dated August 21, 2025, you requested a country of origin determination ruling for the water
dispensers for the purposes of applying current trade remedies.
The merchandise under consideration is water dispensers. The water dispenser is a free-standing, electric
device that dispenses clean, temperature-controlled water. The water dispenser is sold individually in a
single, packaged unit.
All models consist of a water source and reservoir, a heating and cooling system, and a dispensing
mechanism. The product is powered by electricity, allowing it to heat or chill the water as needed.
Specifically, each water dispenser is comprised of a power cord, cold tank, compressor, temperature
controller, (of Chinese-origin), evaporator, condenser, hot tank (of Thai-origin).
There are four platform models of the water dispensers. Differences among the four platform models of water
dispensers are limited to minor variations in exterior design, faucet configuration, and control panel layout.
These four platform models of the water dispenser are consistent in terms of core functionality, internal
component structure, and manufacturing quality, and will be referred to as the same water dispenser for the
purposes of this ruling request. All water dispenser platforms have the same manufacturing process in
Thailand.
You present the following manufacturing process scenario, in which the water dispensers are manufactured in
Thailand through a manufacturing and assembly process comprising of three main stages. The total process
requires 93-96 workers depending on platform, and each stage of the process is carried out by workers using
heavy machinery and equipment to ensure precision and adherence to design specifications. The process
encompasses critical operations such as bending, welding, stamping, assembly, fastening, and testing. These
steps collectively result in a fully assembled and quality-checked water dispenser:
Manufacturing of Key Components
Key water dispenser components are manufactured in Thailand using steel, copper, and aluminum
materials. The condenser, evaporator, and hot tank undergo specialized processes such as tube
bending, resistance welding, stamping, and component assembly using heavy machinery and welding
equipment. Each part follows a defined sequence to meet structural and performance standards, with
7–15 workers assigned per component line. These operations ensure durability, precision, and
consistency across all units.
Subassembly Processes
After producing key components, subassemblies for the water dispenser are assembled in Thailand.
The front shell subassembly involves five workers installing the spout, display, faucet, and fixing
block using screws to ensure alignment and structural integrity. The hot tank subassembly, handled by
four workers, includes mounting sensors, wiring the faucet, and securing the tank and silicon pipe to
the support frame. The cold tank subassembly, also requiring four workers, involves attaching the
evaporator, gluing the sponge, fastening the tank to the supporter, and performing bending operations.
Each subassembly is constructed using specialized tools to meet design and functional standards.
Final Assembly and Testing
In the final stage, 52-53 workers complete the water dispenser assembly in Thailand using
subassemblies and additional components. The process includes securing structural parts like the
base, tanks, and compressor, followed by electrical wiring and refrigerant charging. Leak detection is
performed using halide and leakage test machines, and safety tests to ensure compliance with
operational standards. Final steps include assembling covers, applying labels, and conducting visual
inspections. Units are then packaged using protective materials and cartons, ensuring each product
meets quality and safety requirements before shipment.
When determining the country of origin for purposes of applying current trade remedies under Section 301,
the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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).
This office reviewed the provided assembly process information, and is of the opinion that the Chinese
components undergo processing in Thailand which results in a substantial transformation, such that these
components lose their individual identities and become an integral part of a new article, possessing a new
name, character, and use. In addition, essential parts are manufactured in Thailand. Accordingly, from the
details submitted, we agree that the country of origin for the water dispensers would be Thailand.
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 Michael Chen at [email protected]
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division