N359001

N359001 March 10, 2026 CLA-2-84:OT:RR:NC:N1:105 CATEGORY: Classification; Origin TARIFF NO.: 8421.21.0000 Misty Gibbins Pacific Customs Brokers Inc. 2150 Peace Portal Dr. Blaine, WA 98230 RE: The tariff classification, country of origin, and eligibility of the United States-Mexico-Canada Agreement of an Electrochemical Water Purification System Dear Ms. Gibbins: In your letter dated February 19, 2026, on behalf of your client, Axine Water Technologies Inc., you inquire whether an Electrochemical Water Purification System is eligible for duty free treatment under the United States-Mexico-Canada Agreement (USMCA). You also request a classification and country of origin ruling for marking purposes. Descriptive literature was provided for our review. The merchandise under consideration is described as an Electrochemical Water Purification System, consisting of two reactor vessels, a DC power supply, a plate-and-frame heat exchanger, and associated piping and control equipment. In operation, a direct current (DC) is applied to the reactors, which contain anode and cathode surfaces. The applied current induces electrochemical reactions on these surfaces that oxidize and/or reduce pollutants in the feed water. The system may also generate oxidants (such as hydrogen peroxide or hydroxyl radicals) that further react with contaminants. The process also generates heat, which is removed by the system’s plate-and-frame heat exchanger connected to an external cooling source. The treated effluent is discharged as purified water and the treated wastewater is disposed. The system is enclosed within a modified 20' high cube (HC) steel container equipped with exterior access panels and a walk-in entrance door providing access to the interior. Each of the primary modules are fully assembled in Canada from components sourced worldwide. These modules include the purge air skid, reactor feed skid, heat exchanger skid, reactor manifold skid, clean in place skid, reagent dosing system, transfer skid, main distribution panel, and reactor power panel. The Canadian components include clamps, wire cable trays, brackets, couplings, washers, screws, fittings, chem secondary containment, a modified 20' HC container, plates, motors, and EOX reactors. The U.S. components include fittings, clamps, tubes, nozzles, pipe, bushings, flanges, gaskets, pumps, filters, sensors, reactor tank, a purge air scrubber, and flow transmitters. The Mexican components include transformers and outlet boxes. The remaining components are all sourced outside of North America. The Chinese components include nuts, bolts, screws, bushings, fittings, straps, channels, springs, receptacles, strainers, temperature transmitters, and analytical transmitter conductivity. The remaining small parts are sourced from Switzerland (glue sockets and scales), Turkey (cables), the United Kingdom (switches and sensors), Thailand (washers, nuts and screws), Italy (chemical resistant discs and buttons), India (brass connectors), Taiwan (purge air blower and screws), India (washers), Austria (strainers), Germany (pumps, switches, nozzles, injection quill, and connectors), Indonesia (LED light stack), Japan (mounting bracket and plugs), Poland (heat exchanger), and Hungary (switches). The manufacturing process starts in Canada with the modification of the cube steel container. The skid frames are then assembled outside the container by mounting the individual components and equipment onto the frame with brackets before the PVC and CPVC pipe is cut, glued, and installed. Next, the pipes are attached to the pumps and other equipment on the frame. The instrumentation is then mounted either directly onto the piping or using additional brackets before sliding the finished skid into the container. As more skids are added to the container they are interconnected with piping. Electrical and control cables are pulled from the panel and connected to each piece of equipment and instruments. Finally, after all of the components are installed and connected, the complete unit is tested before being shipped. CLASSIFICATION The applicable subheading for the Electrochemical Water Purification System 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. ORIGIN In regard to marking, 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. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). 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. Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in sections 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining the country of origin of a good for marking purposes, with the exception of textile and apparel goods which are subject to the provisions of 19 CFR 102.21. See 19 CFR 102.11. Applied in sequential order, 19 CFR 102.11(a) provides that the country of origin of a good is the country in which: (1) The good is wholly obtained or produced; (2) The good is produced exclusively from domestic materials; or (3) Each foreign material incorporated in that good undergoes an applicable change in tariff classification set out in Part 102.20 and satisfies any other applicable requirements of that section, and all other applicable requirements of these rules are satisfied. Here, the Electrochemical Water Purification System is neither “wholly obtained or produced” nor “produced exclusively from domestic materials.” Consequently, paragraphs (a)(1) and (a)(2) cannot be used to determine the country of origin of the Electrochemical Water Purification System, and paragraph (a)(3) must be applied to determine the origin of the finished article. As mentioned above, the subject assembly is classified under subheading 8421.21. The tariff shift requirement in Section 102.20 for a good classified within this subheading requires a change to subheading 8421.11 through 8421.39 from any other subheading, including another subheading within that group. A review of the bill of materials indicates that the country of origin cannot be determined under §102.11(a)(1), (2), or (3), as the strainers and filters, sourced from China and Austria, do not undergo the required tariff shift specified in 102.20. 19 CFR 102.11(b) provides that where the country of 

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 jason.m.christie@cbp.dhs.gov. 
Sincerely,
 (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division