N350783

N350783 July 29, 2025 CLA-2-84:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 8421.21.0000; 9903.01.24; 9903.01.25; 9903.88.01 Enrique Perez Plasticos Promex DBA Quantum Plastics 1220 Barranca, Building 4C El Paso, TX 79935 RE: The tariff classification and origin of a purifier bottle from China Dear Mr. Perez: In your letter dated June 30, 2025, you requested a tariff classification and country of origin ruling for a purifier bottle. Descriptive literature was provided for our review. The item under consideration is described as the 24 oz. GeoPress Ti Purifier Bottle. The device is made from CP4 Grade 1 Titanium and is designed to filter and purify water at any freshwater source (lakes, streams, rivers, etc.). The bottle provides fresh drinking and cooking water in a camping or outdoor environment without the use of electricity. The advanced filter cartridge houses a proprietary nonwoven filter media, which enables the core water purification functionality by removing submicron biological, chemical, and particulate contaminants. The replacement cylindrical filter cartridge is inserted by the user into the rigid titanium inner before being inserted into the titanium outer. The addition of the top cap completes the press-style filtration system. In operation, the user scoops water from the source with the titanium outer, then adds the titanium inner (that includes the top cap and filter cartridge) before pressing down into the untreated water. The water is forced through the cartridge’s internal filter media, which in turn captures viruses, bacteria, protozoa, particulates, chemicals, and heavy metals. The result is purified drinking or cooking water produced within only a few seconds of operation. The applicable subheading for the 24 oz. GeoPress Ti Purifier Bottle 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. In your letter, you also requested a determination on the country of origin for the purpose of applying current trade remedies. The 24 oz. GeoPress Ti Purifier is assembled in Mexico from components made in China, Mexico, and the United States. The Chinese components include the titanium inner, silicone titanium inner body collar, titanium outer, titanium cook lid, filter cartridge assembly (which includes a Chinese silicone seal, Chinese silicone O-ring, and a U.S.-origin filter media), silicone one-way valve, silicone gasket, screws, nut, and packaging. The Mexican components include the plastic lid assembly that includes the lid polypropylene (PP) and thermoplastic elastomer (TPE) overmold, strap PP and TPE overmold, and the cap core PP and TPE overmold. The manufacturing of the cartridge starts with the creation of the non-woven electro-adsorptive filter media, which is manufactured in the United States and requires 60 skilled workers and dedicated industrial equipment to produce. The process begins with melt-blown fiber extrusion to create high-aspect-ratio alumina/glass continuous fibers. Then, slurry blending occurs with cellulose pulp and activated carbon fibers in a precise weight ratio. Next, the web formation is created on a flat wire fourdrinier paper machine to produce a highly uniform composite followed by the lamination of multiple fiber layers under precise heat, tension, and time controls. The surface is then treated with proprietary compounds to increase electropositive charge density before cutting and quality control testing for flow rate, microbial retention, and contaminant removal. Finally, bio-testing occurs to ensure efficacy in the removal of biological pathogens, inorganics, and heavy metals. The manufacturing process then shifts to China where the U.S.-origin filter media is pleated into cylindrical form, hot-sealed into pleat packs, and inserted into Chinese produced polypropylene plastic end caps, which are then glued and cured. Two silicone O-rings are then affixed to complete the cartridge. The assembly process in Mexico starts with obtaining all of the Chinese, U.S. and Mexican components. The plastic lid assembly, that includes the PP and TPE overmold, strap PP and TPE overmold, and the cap core PP and TPE overmold, are all manufactured in Mexico before starting the assembly process. Once all items are obtained, workers assemble the top cap and combine the Chinese produced titanium inner with the titanium outer and silicone titanium inner body collar. Then the top cap is screwed into place. The filter cartridge assembly is then screwed onto the bottom of the titanium inner after the silicone one-way valve is placed. After the assembly is complete, the item is inspected and packaged for shipment to the United States. 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 for the purpose of applying current trade remedies, several of the core components including the titanium inner, titanium outer, and silicone one-way valve are all manufactured in China prior to shipping to Mexico for final assembly. The replacement filter cartridge is assembled in China but contains the proprietary U.S.-origin non-woven electro-adsorptive filter media. The assembly process in Mexico, involves taking the Chinese components and U.S. filter cartridge and performing simple actions such as screwing and pressing items into place. The addition of the Mexican lid components adds to the finished nature of the article but does not change the primary function of the filtering bottle. In order to perform the filtering function, the user must have the filtration cartridge, the titanium inner and the titanium outer. Missing any of these core components would not allow the item to perform the filtering function. Therefore, it is our view that the Chinese components are not substantially transformed into a different article of commerce with a new character and use. The components, while disassembled and requiring a few additional items, are specifically designed to be a press-style filtration system and cannot be used for any other purpose. The titanium components contain the highest cost of the overall filtration system and also contains the shape and size of the finished product. As such, the country of origin of the 24 oz. GeoPress Ti Purifier will be China for the purpose of applying current trade remedies, which is where the titanium components are manufactured prior to simple assembly. In regards to marking, Section 304, Tariff Act of 1930, as amended (19 U.S.C. § 1304), provides that, unless excepted, every article of foreign origin (or its container) 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. Part 134 of the U.S. Customs and Border Protection (CBP) Regulations (19 C.F.R. Part 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. § 1304. The “country of origin” is defined in 19 CFR 134.1(b) as “the country of manufacture, production

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 for the purpose of applying current trade remedies, several of the core components including the titanium inner, titanium outer, and silicone one-way valve are all manufactured in China prior to shipping to Mexico for final assembly. The replacement filter cartridge is assembled in China but contains the proprietary U.S.-origin non-woven electro-adsorptive filter media. The assembly process in Mexico, involves taking the Chinese components and U.S. filter cartridge and performing simple actions such as screwing and pressing items into place. The addition of the Mexican lid components adds to the finished nature of the article but does not change the primary function of the filtering bottle. In order to perform the filtering function, the user must have the filtration cartridge, the titanium inner and the titanium outer. Missing any of these core components would not allow the item to perform the filtering function. Therefore, it is our view that the Chinese components are not substantially transformed into a different article of commerce with a new character and use. The components, while disassembled and requiring a few additional items, are specifically designed to be a press-style filtration system and cannot be used for any other purpose. The titanium components contain the highest cost of the overall filtration system and also contains the shape and size of the finished product. As such,