OT:RR:NC:N1:105
Icey Huang
Autowin Group Limited
Flat/RM 08, 15/F
Witty Commercial Building
1A-1L Tung Choi Street
Mongkok, Kowloon, Hong Kong
China
RE: The country of origin of air tool filters
Dear Ms. Huang:
In your letter dated October 1, 2026, you requested a country of origin ruling on air tool filters. Descriptive
literature was provided for our review.
The first item under consideration is described as a 1/4-inch mini air tool filter (item number 1111200196),
which is a compact, point-of-use inline air filtration device specifically designed to attach directly to
pneumatic tools (such as impact wrenches, grinders, and spray guns) or air lines via standard 1/4-inch NPT
(National Pipe Thread) inlet and outlet ports. Constructed with a lightweight, impact-resistant clear
polycarbonate housing, an aluminum alloy cap, and a porous brass element, the unit is designed to trap
airborne solid contaminants, such as pipe scale, rust, and dust, and separate moisture, oil, or condensed water
from compressed air before it enters the air tool. As compressed air passes through the filter element,
particulates are retained, and separated liquid collects at the bottom of the transparent bowl ready to be
drained by the valve.
The second item under consideration is described as a compact 3/8-inch air filter (item number 1111200194),
which is a compact, point-of-use inline air-filtering apparatus designed for installation within pneumatic lines
and compressed air systems. It features a 3/8-inch female NPT inlet and outlet porting arrangement to
channel air streams directly through a high-efficiency filtration matrix, utilizing a bronze filter element. The
filter housing is constructed of an aluminum alloy valve body paired with a transparent polycarbonate bowl
and integrated guard, allowing immediate visibility of captured moisture and debris. Operating under
pressures ranging between 0 and 150 PSI, the device functions mechanically to intercept, coalesce, and
isolate moisture, oil vapor, dust, and rust particles from the compressed air flow before it reaches downstream
air tools or pneumatic machinery. The unit is equipped with a standard drain valve at the base of the reservoir
cup to evacuate gathered contaminants periodically.
The 1/4-inch mini air tool filter is made from components sourced from China and Malaysia. The Chinese
components include the aluminum machining blank (to make the valve body), O-ring, locking collar, filter
element, plastic base, screws, springs, retaining ring, filter bowl, and mounting bracket. The Malaysian
component is the brass round bar used to make the drain valve core and drain valve seat.
The 3/8-inch air filter is made from components sourced from China and Malaysia. The Chinese components
include the aluminum machining blank (to make the valve body), O-ring, locking collar, filter element,
plastic base, filter bowl, metal protective cover, springs, retaining rings, screws, mounting bracket and
locking nut. The Malaysian component includes the brass round bar used to make the drain valve seat, drain
valve core and hex lock nut.
For both filters, the Chinese components are then sent to Malaysia. In Malaysia, the metal components are
constructed using a CNC machining process that starts with precision drilling and deburring and finishes with
a final inspection. Once the metal components are made, they are then assembled with the remaining Chinese
components to form the complete 1/4-inch mini air tool filter and 3/8-inch air filter.
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.
Based upon your description of the manufacturing operations, we note that a significant amount of the
components that comprise the filters are manufactured (CNC machined) in Malaysia. Additionally, these
components along with the Chinese O-ring, locking collar, filter element, plastic base, filter bowl, metal
protective cover, springs, screws, retaining rings, mounting bracket and locking nut emerge with a new name,
character, and use, different from those possessed by the raw materials. Thus, based on the totality of the
circumstances, the country of origin of the 1/4-inch mini air tool filter (item number 1111200196) and the
3/8-inch air filter (item number 1111200194) will be Malaysia.
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)
James P. Forkan
Director
National Commodity Specialist Division