CLA-2-84:OT:RR:NC:N1:105
Justin Fourie
Oak & Mie USA, Inc.
131 Continental Dr, Suite 305
Newark, DE 19713
RE: The tariff classification and country of origin of a water filtration device
Dear Mr. Fourie:
In your letter dated January 20, 2026, 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 the FlavaFil Filter, which is an all-in-one, universal, and
modular straw system designed to transform standard water bottles into advanced, customizable hydration
stations. Featuring a two-stage process, it combines an electro-adsorptive filtration technology, capable of
reducing contaminants like lead, chlorine, and microplastics, with a “FlavaChamber” that allows users to
infuse water with powders, electrolyte mixes, cold-brew teas, or syrups without staining or contaminating the
bottle. The system employs a Venturi design for smooth, consistent flavor blending as you sip,
complemented by an adjustable “FlavaControl” dial to personalize flavor intensity. The device is reusable,
dishwasher-safe, and provides approximately 30 days of purified and customized drinking per filter.
The FlavaFil is comprised of components manufactured in Singapore and China. The water filtration
cartridge is produced in Singapore. This cartridge contains the filtration media and performs the sole
water-purifying function of the finished product. The Assembled Straw Housing (structural housing and fluid
control that includes the mouthpiece and valve), Flavor Bullet - Powder (holds externally supplied powder
flavoring), Flavor Bullet - Syrup (holds externally supplied syrup flavoring), and Silicone Straw (conveys
filtered water to the user), are all manufactured in China.
The water filtration cartridge is fully manufactured in Singapore, including filtration media production,
cartridge assembly, and functional testing. The plastic housings and non-filtration components (such as the
straw, and flavor bullets) are all manufactured in China. To assemble the FlavaFil, the Singapore-origin
filtration cartridge is shipped to China, where it is inserted into the plastic housing before the straw and
Flavor Bullets are pressed into place. This is followed by sealing the individual components and final
packing.
The applicable subheading for the FlavaFil Filter will be 8421.21.0000, 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: For filtering or purifying water.” The general rate of duty will be free.
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 FlavaFil Filter, it is our opinion that the manufacturing and assembly process
performed in China is not considered complex. Therefore, we look to determine the component that imparts
the character and use of the device. In this instance, the water filtration cartridge is produced in Singapore,
represents almost half of the finished article’s value, and provides the sole water filtration function. While
additional components are added in China, these components do not transform the filtration cartridge into a
new article with a new, character, and use. Therefore, in our opinion, the country of origin of the FlavaFil
Filter is Singapore, which is where the filtration cartridge is manufactured.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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