CLA-2-84:OT:RR:NC:N1:105
Lina Ying
Gaumann Filtration Sdn.Bhd
No. 57, Jalan i-Park SAC 7, Taman Perindustrian I-Park SAC, 81400
Senai, Johor
Malaysia
RE: The tariff classification and country of origin of an oil filter
Dear Ms. Ying:
In your letter dated October 22, 2025, you requested a tariff classification and country of origin determination
ruling. Descriptive literature was provided for our review.
The item under consideration is described as an automotive oil filter (model WT504612S), 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 cold steel raw material, electroplate steel wire, hot-dip galvanized steel
sheet, heat curing adhesive, diaphragm, O-ring, sealing plate, toothless cover plate, sealing ring, and some of
the packaging material including the boxes and labels. The remaining items, other than the South Korean
filter paper, are from Malaysia and include the spin-on oil filter, spray shell assembly, shell, white powder,
oil filter element assembly, upper end cover, central tube, origami, retainer clip, lower end cover assembly,
media end plate, bypass valve sea, bypass valve disc, screw-fit plate assembly, threaded cover plate, and the
rest of the packaging including boxes, dust film, pallets, and corner protectors.
The manufacturing process occurs in Malaysia and starts with creating the metal housing using a press
machine and then stretch forming of the spin-on oil filter housing using the 200T Press Machine with robotic
arm. The metal is placed onto the rack where a mold draws out the shape and the excess material is trimmed.
The next step includes the housing powder coating. The newly formed metal housing has the powder sprayed
onto it before being inspected for flaws. The next process is the pleating process, which starts with a roll of
filter paper that is pleated via an automated filter paper pleating machine. The material then goes onto the
slitting machine for proper slitting according to the specifications provided on the product drawing. The
center tube is then created by being punched, embossed, and cut to fixed lengths and into shape. Next, the
stamping machine creates the upper and lower end covers before the oil filter center tube is added while also
adding the rivets, springs, and seals. Then, the pleated filter paper is placed onto the automatic paper splicing
equipment. The thermosetting adhesive is then added before adding the end caps and baking in an oven.
Next, the cap cover plate is placed in the tapping equipment and spot welded into place. The final assembly
includes adding the O-rings, sealant, anti-drain valve, spring, and paper core into place. Then, all items are
sealed, and a leak test is performed before final labeling and packaging.
The applicable subheading for the oil filter (model WT504612S) 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 transforms the Chinese components (the cold steel raw material, electroplate steel wire, hot-dip
galvanized steel sheet, heat curing adhesive, diaphragm, O-ring, sealing plate, toothless cover plate, sealing
ring) and South Korean filter paper into a new article with a name, character and use, different than the
individual components. Therefore, in our opinion, the country of origin of the oil filter (model WT504612S)
is Malaysia, which is where the majority of the components are sourced, and the final manufacturing and
assembly steps are completed.
Effective May 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobile
parts. Additional duties on automobile parts of 25 percent are reflected in Chapter 99, heading 9903.94.05, as
provided in subdivision (g) of U.S. note 33 to this subchapter. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.94.05, 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 Malaysia will be
subject to an additional ad valorem rate of duty of 19 percent. Your product falls within an excepted
subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.33, 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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division