OT:RR:NC:N1:102
James Amyx
Sandler, Travis & Rosenberg, P.A.
5835 Waterford District Drive, Suite 200
Miami, FL 33126
RE: The country of origin of a compressor
Dear Mr. Amyx:
In your letter dated March 31, 2026, on behalf of your client, Universal Air Conditioner, LLC., you requested
a country of origin ruling on a compressor to apply current trade remedies and for marking purposes. It is
noted that this office previously addressed the country of origin of a similar compressor used in an air
conditioning system of a motor vehicle for the same requester. See New York Ruling Letter N355567, dated
November 26, 2025,
The product at issue is a compressor, model number CO 29162C. The compressor is designed to be installed
in a motor vehicle and connected to the belt system of the engine. Once powered, the swashplate turns to
drive the slippers, converting the rotary motion of the main shaft into the reciprocating motion of the
compressor’s pistons, which move back and forth. The resulting motion pressurizes and displaces gas used in
the air conditioning system.
With respect to origin, the final assembly of the compressor occurs in South Korea using components from
South Korea and China. Prior to the final assembly, the front and rear cylinder blocks, the front and rear
housings, the swashplate, the pulley, the main shaft and arm, the coil and the clutch hub are produced in
South Korea.
To produce the housings and blocks, raw metal from South Korea is melted in a furnace and subsequently
pressed into a mold. Afterwards, the resulting cast is deburred, shot blasted and machined. During the
machining processes, the threaded holes and mounting grooves are formed using boring and facing
operations.
The swashplate from South Korea is machined on the surface and inner and outer diameters.
To form the main shaft and shaft arm, raw material is sourced from China and forged. Afterwards, the
forgings are quenched and tempered. Afterwards, the ends are drilled, machined, hardened and coated.
To form the pulley, the outer surfaces of a forging blank from China are turned. The belt grooves are
machined, a central hole is drilled and all edges are chamfered. The burrs are removed, and the bearing seat is
finished. The pulley is then hardened and coated.
To form the coil, copper wire from South Korea is cut, stripped and connected to electrical terminals using a
crimping process. Subsequently, the coil is inserted into a steel housing and afterwards wound and
magnetized.
To form the clutch hub, a rubber molded component, an armature, and rivets from South Korea are
assembled to each other. The subassembly is then inserted into a grinding machine to achieve a specific
flatness and surface finish.
The final assembly begins by positioning and pressing a main shaft onto a swashplate. Afterwards, the
resulting swashplate subassembly is clamped to five pistons and ten slippers from China. In sequence,
bearings from China and the swashplate subassembly are pressed into a front cylinder block. Next, a rear
cylinder block is installed, lubricant is applied, and a shaft seal and retainer are installed. The process
continues by combining pins, washers, a plate from China, and a suction valve from China. Afterwards, an
oil plug from China is installed, and a seal is pressed onto the front cover. Once the cover is installed into the
cylinder block, a valve plate assembly is installed, the plug is filled with oil, and a pressure relief valve is
installed into the rear housing. Finally, a coil subassembly and a pulley are pressed onto the cover, a wire
clamp and a clutch hub are installed, and the housings are secured in place. Each compressor is packaged
ready for shipment. Testing and inspections are completed throughout the process.
When determining the country of origin for purposes of applying current trade remedies under Section 301
and additional duties, 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).
Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless
excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous
place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a
manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin
of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be
able to know by an inspection of the marking on the imported goods the country of which the goods is the
product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may,
by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should
influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940).
Part 134 of the U.S. Customs and Border Protection (CBP) Regulations (19 CFR 134) implements the
country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP
Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or
growth of any article of foreign origin entering the United States. Further work or material added to an article
in another country must effect a substantial transformation in order to render such other country the “country
of origin” within the meaning of the marking laws and regulations.
CBP has held that whether an assembly process is sufficiently complex to rise to the level of a substantial
transformation is determined upon consideration of all the operations that occur within that country. Here,
various components that play a significant role in the compression of air are produced in South Korea and
afterwards combined with components from China to form a compressor in South Korea. When considering
the totality of the circumstances, this office finds that the processes that occur in South Korea are sufficiently
complex and meaningful as to result in a substantial transformation, such that the non-originating
components lose their individual identities and become an integral part of a new article, possessing a new
name, character and use. Based on the processes described in the submission, we find the country of origin of
the compressor is South Korea.
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 Sandra Martinez at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division