OT:RR:NC:N1:105
Chengyue Liu
Midea (Egypt) Kitchen & Water Heater Appliance Co. Ltd
North-West Gulf of Suez Economic Zone
Ain Sokhna Suez
Egypt
RE: The country of origin of dishwashers
Dear Mr. Liu:
In your letter dated January 14, 2026, you requested a country of origin ruling on dishwashers. Descriptive
literature was provided for our review.
The items under consideration are described as High Polaris Dishwashers (models WQP12-5901K-US,
WQP12-59M6-US, WQP12-5909V-US, WQP12-5909W-US, and WQP12-59E1-US). These built-in
household dishwashers are designed to fit under kitchen counters and clean tableware using hot water,
detergent, and rotating spray arms. Each unit is sold as a complete packaged system and incorporates four
primary subassemblies: the inner tub (the main washing chamber), the chassis (structural framework for
mechanical and electrical components), the upper and lower baskets (for secure dish placement), and the air
breather (which regulates air pressure in the water line).
In Egypt, manufacturing is executed by integrating locally sourced elements with parts sourced from China.
The Egyptian-origin components include the connecting board, lower basket, steel wire, cutlery basket,
lampstand, float seat, float shrapnel, floater, back board, tub middle plate, stiffeners, sealing frame, angle
plate, upper back support, base tray cover, lower sprayer assembly, lower sprayer shaft, air breather, snap
ring, connector, middle sprayer pipe, upper sprayer, and the upper basket. Conversely, the Chinese-origin
components include absorbent cotton, screws, galvanized sheet, gaskets, brackets, plastic powder, modified
plastic particles, clamps, caps, pipes, control panel, stickers, display printed circuit board (PCB), door lock,
filter handle, handle box, induction pump, valves, junction box, main control panel, wire harness, switches,
pins, sealing rings, plastic sleeves, rail support, rope pulley, valve covers, wheel, and waterproof silicone pad.
The first of five stages in the process includes the injection molding, which produces key plastic components
such as sprayer parts, float assemblies, the cutlery basket, connectors, and support structures. Polypropylene
and color masterbatch are dried, mixed, injected into molds, cooled, trimmed, and inspected before mass
production proceeds.
The second stage involves metal stamping. Steel coil sheets are used to form the outer door and side panels
through cutting, drawing, punching, flanging, and shaping, after which damping material is applied and
cured. Stainless steel plates undergo similar processes to create the inner door, tub middle plate, and back
board, while the sealing frame is shaped using a forming machine. Additional components such as stiffeners,
connecting boards, and angle plates are produced by a third-party vendor through precision stamping and are
inspected for quality.
The third stage is subassembly production. The inner tub subassembly is created through bending, riveting,
welding, sealing, and curing, with stiffeners, sealing frames, hinge supports, and guide rails added during
assembly. The upper and lower baskets are hydroformed, spot-welded, powder-coated, and fitted with rollers,
spray arms, and a cutlery rack. The chassis subassembly is built by installing the heating tube, control board,
sensors, drain pump, thermostat, inlet valve, wiring harnesses, guide wheels, and other functional elements.
The fourth stage is final assembly. Workers install the respirator, drainpipe, wiring harnesses, spray arms,
inner door, decorative panel, and water inlet components. They also test the water inlet for proper
performance and check for leaks. The structural enclosure, including side panels, baseboard, and outer door,
is attached and secured to complete the unit.
The fifth and final stage consists of testing, inspection, and packaging. Each dishwasher undergoes electrical
safety testing, functional checks, and detailed visual inspection to confirm proper alignment, sealing,
labeling, and appearance. After passing all evaluations, each unit is packaged with foam inserts and corner
guards before being sealed in a protective carton.
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 High Polaris Dishwashers (models WQP12-5901K-US, WQP12-59M6-US,
WQP12-5909V-US, WQP12-5909W-US, and WQP12-59E1-US), it is our opinion that the Chinese
components undergo a substantial transformation in Egypt. The integration of various components through
Egyptian manufacturing results in a substantial transformation, creating a new article of commerce with a
distinct name, character, and use. Consequently, the country of origin for High Polaris Dishwashers is Egypt,
the site of the primary manufacturing and assembly operations.
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)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division