N352739

N352739 September 17, 2025 OT:RR:NC:N1:102 CATEGORY: Origin Nate Bolin K&L Gates LLP 1601 K Street, NW Washington, DC 20006 RE: The country of origin of rooftop air conditioning units Dear Mr. Bolin: In your letter dated August 21, 2025, you requested a country of origin ruling on behalf of your client, Midea Intelligent Manufacturing (Thailand) Co., Ltd. The articles at issue are MIT rooftop air conditioning units, model numbers TR-WKC297A/WN10XB and TR-WKC437A/WN10XB. The units consist of a chassis comprised of plates and a frame that encloses compressors and various subassemblies, such as the condenser and evaporator subassemblies. The air conditioning units are designed to cool living spaces or small offices and have an output that exceeds 17.58 kilowatts per hour. With respect to origin, the final assembly of each unit occurs in Thailand using components and subassemblies from Thailand and other countries. Before the final assembly, the components that make up the chassis are manufactured in Thailand using stamping and pressing processes. The galvanized steel sheets are then uncoiled and bent to shape to be shaped into framework components. Then, to form the frame, four crossbeams are bolted to each other, and the six protective plates are screwed to the crossbeams. A wooden frame is then placed on top of the six plates. Next, an electro powder coating is applied, a waterproof plate is screwed in place and insulation is taped in the appropriate locations. To form the external end plates, which feature the supply air outlet and return air inlet, processes such as welding, coating, gluing and applying aluminum tape occur. To form the air duct panels, boards are welded, followed by a gluing process. In addition to the housing and framework, various subassemblies such as condenser and evaporator subassemblies, the expansion valve subassembly, the exhaust and suction pipe subassemblies, and the supply and return air subassemblies are produced in Thailand. The production of the condenser and evaporator subassemblies begins by punching holes in pre-cut plain pipes. The pipes are then grooved, cut with slits and cleaned. Afterwards, spacers, caps, brackets and adapters are installed, and the fins are formed using stamping and cutting processes. Next, the copper pipe is swaged, the aluminum pipe is flared, and the pipes are then welded and bent, which is followed by the installation of the aluminum fins. In the following step, the slide plates are installed, and the manifolds are assembled to the pipe core assembly. Subsequently, binding, spraying and welding processes occur, and the inlet and outlet pipes are welded to the core assembly, which is subsequently charged and tested. To complete the two condenser subassemblies, copper pipe is cut to length, bent, flared and welded to the input and output sections of heat exchange units. Then, two sensor attachment sleeves are welded to the pipes. Afterwards, the condenser subassemblies are injected with gas. To form the evaporator subassembly, an input pipe is formed by cutting and bending copper pipe. Subsequently, the shaped pipes are inserted into the distributor and welded in the joint area. Next, copper pipe is cut, bent and flared. The flared pipes are then welded to each other and the L-shaped pipes to form the outlet subassemblies. The input and output subassemblies are then welded to a heat exchange unit and filled with gas. To form the filter installation box for the evaporator, a filter installation box is riveted to five plates. Afterwards, rubber grommets are installed. To form the expansion valve subassembly, copper pipe is cut to length and flared. Connecting pipes are welded to a filter, and two holes are bored into a connecting pipe, in which a capillary transition pipe is inserted. Afterwards, an L-shaped pipe is formed and welded to a valve, which is then welded to the capillary transition pipe. Finally, rubber pads and pipes are installed. To form the suction pipe and exhaust pipe subassemblies, copper pipe is cut to length, bent and narrowed at the ends. Depending on the subassembly, the pipes are subjected to processes, such as welding to filters, the shaping of bores to incorporate a valve, and the securing of a pressure switch. For the waterproof box subassembly, two boxes are riveted to each other. The assembly is then coated, and sponges are secured to the assembly using glue. To form the drainage subassembly, a pan and board are welded to each other and coated. During the final assembly, two compressors are screwed onto a chassis (two from South Korea or one from South Korea and one from China). This is followed by the installation of a guide rail subassembly, a support plate, an air duct enclosure and a drainage pan. Next, partition panel subassemblies, an air duct subassembly, a middle rear vertical pillar assembly, and an evaporator subassembly are installed using screws. A filter installation box is connected to the evaporator subassembly, the front and rear pillar subassemblies are installed, and then two condenser subassemblies are screwed onto the chassis. Subsequently, the connections for the exhaust pipe, valve and suction pipe subassemblies are welded. In the following step support plates, air and return panel subassemblies, the front middle pillar subassembly and the partition panel subassembly are attached. Next, a fan subassembly, a support plate, a motor and a pulley system are installed, and the inner and outer top covers are placed using screws. Subsequently, a sensor and wiring harness, a protective plate subassembly, a waterproof box subassembly, and two electrical control box covers are installed. Afterwards, the appropriate wiring connections are completed, and the side panels are screwed in place. The finished unit is labeled, tested, inspected and packaged for shipment. 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 (HQ) 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 this instance, components sourced from South Korea (compressors), China (compressors) and Thailand, including other subassemblies that contribute to the change of temperature process (an evaporator and two condenser subassemblies) and the chassis, are assembled to each other in Thailand to produce an air conditioning unit. A similar scenario regarding the origin of an air conditioning unit was discussed in HQ Ruling Letter H320037, dated November 18, 2021. In this ruling, the country of ruling of the unit was based on the origin of the components that make up the cooling system and the final assembly processes. In applying the same origin rationale, we find the origin of the air conditioning units is Thailand. 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) an

is applicable. See, e.g., Headquarters (HQ) 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 this instance, components sourced from South Korea (compressors), China (compressors) and Thailand, including other subassemblies that contribute to the change of temperature process (an evaporator and two condenser subassemblies) and the chassis, are assembled to each other in Thailand to produce an air 

conditioning unit. A similar scenario regarding the origin of an air conditioning unit was discussed in HQ Ruling Letter H320037, dated November 18, 2021. In this ruling, the country of ruling of the unit was based on the origin of the components that make up the cooling system and the final assembly processes. In applying the same origin rationale, we find the origin of the air conditioning units is Thailand. 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 i