CLA-2-84:OT:RR:NC:N1:105
Chris Wang
Qingdao Ecopure Filter Co., Ltd.
No.13, Yishengbai Road, Jimo
Qingdao 266201
China
RE: The tariff classification and country of origin of replacement water filters
Dear Mr. Wang:
In your letter dated March 26, 2025, you requested a tariff classification and country of origin ruling on
replacement water filters. Descriptive literature was provided for our review.
The items under consideration are replacement water filters for electric water dispensers, identified as model
numbers WD-EDF, WD-EDFA, WD-EDFX, WD-EDFC, BW-WD-EDF-1, AQC-ED16 and EFF-6016A.
The filters generally follow the same structure and packaging steps, with the only differences being a slight
change in size, shape and brand name. The products are lead-free and are certified to reduce 97% of chlorine,
contaminants, and odor for better tasting water. The filters are to be discarded and replaced by a consumer
approximately every three months.
As you suggest in your letter, the applicable subheading for the WD-EDF, WD-EDFA, WD-EDFX,
WD-EDFC, BW-WD-EDF-1, AQC-ED16 and EFF-6016A replacement water filters will be subheading
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 is free.
The filters are assembled in China using components manufactured in South Korea and China. The filter
element is composed of a Chinese O-ring, upper cover, middle cover, bottom cover, sump, transparent
protective film, and a South Korean carbon block.
The carbon block removes contaminants from water through a process called “adsorption.” Adsorption is a
process in which contaminants are attracted to the surface of the carbon granules and become trapped in the
small pores of the filtration media. The carbon block requires substantial processing to create and accounts
for the largest cost of the overall filters.
The entire production and packaging process includes nine steps and is completed by eleven workers. It is
divided into two parts: filter element assembly and product packaging. The filter element assembly consists
of five steps and is completed by six workers. The first step in the filter assembly process involves one
worker manually inserting the O-ring into the middle cover/top cover. During this step, visual inspection is
conducted to ensure there are no scratches, stains, or color differences. The next step involves one worker
operating glue dispensing equipment to glue the middle cover, carbon rod, and bottom cover together. During
this step, the carbon block is pressed vertically without damaging it and it is evenly bonded. The third step
involves one worker operating a rotary welding machine to weld and bond the upper cover, glue-dipping
carbon rod, and sump to form a complete filter element. Finally, a self-inspection is performed to check that
the product is free from stains, overflowing glue, cracking, etc. This is followed by an air tightness test,
labeling, and final packaging.
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).
In regard to the country of origin of the replacement water filters, it is our opinion that the assembly process
performed in China is not complex and does not constitute a substantial transformation. The process
predominantly involves gluing, welding, and pressing various components into place. The combining of these
parts in China does not create a new and different article of commerce with a name, character, and use
distinct from the individual components. Therefore, to determine the country of origin of the replacement
water filters, we rely on the origin of the carbon block, which provides the essential function of the filters. It
is the carbon block from South Korea which requires considerable technical expertise and customized
equipment to produce. It is also the most expensive portion of the filters and is the item performing the
filtering of the water. Accordingly, the country of origin of the WD-EDF, WD-EDFA, WD-EDFX,
WD-EDFC, BW-WD-EDF-1, AQC-ED16 and EFF-6016A replacement water filters will be South Korea,
which is where the carbon block is manufactured.
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. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to
subheading 8421.21.0000, HTSUS, listed above.
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/current
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,
Steven A. Mack
Director
National Commodity Specialist Division