N353476

N353476 October 1, 2025 CLA-2-84:OT:RR:NC:N1:105 CATEGORY: Classification; Origin TARIFF NO.: 8421.23.0000; 9903.01.24; 9903.94.05; 9903.01.33; 9903.88.03 Lina Ying Gaumann Filtration Sdn.Bhd No. 57, Jalan i-Park SAC 7, Taman Perindustrian I-Park SAC, 81400 Senai, Johor Malaysia RE: The tariff classification and country of origin of an oil filter Dear Ms. Ying: In your letter dated September 9, 2025, you requested a tariff classification and country of origin determination ruling. Descriptive literature was provided for our review. The item under consideration is described as an automotive oil filter (model WT505335), which is designed for use in the lubrication system of internal combustion engines, specifically in passenger vehicles and light-duty trucks. The filter removes impurities and particulate matter from engine oil to ensure proper lubrication and engine protection in both gasoline and diesel engines. The outer casing of the filter is made of a corrosion-resistant steel while the filter media is made from synthetic fiber or cellulose, which is used to trap particulates. The end caps and center tube are metal or plastic structures that provide support to the filter media. The filter also has a rubber or metal anti-drain back valve and bypass valve that regulates oil flow and prevents oil leakage. The oil filter is attached to the engine via a threaded fitting on the base plate, which screws onto the engine’s oil filter mount. The rubber gasket creates a tight, pressure-resistant seal between the filter and engine block to prevent oil leaks during operation. The Chinese components include the housing assembly, upper end cover, heat curing adhesive, galvanized thin sheet, filter paper, lower-end cover assembly, diaphragm, cap assembly, sealing ring, and some of the packaging material including the boxes and labels. The remaining items are from Malaysia and include the spin-on oil filter, oil filter element assembly, central tube, origami, and the rest of the packaging including boxes, dust film, pallets, shrinkable film, and corner protectors. The manufacturing process occurs in Malaysia and starts with creating the metal discs using a press machine and then stretch forming of the spin-on oil filter housing using the 200T Press Machine with robotic arm. The metal is placed onto the rack where a mold draws out the shape and the excess material is trimmed. The next step includes the housing powder coating. The newly formed metal housing has the powder sprayed onto it before being inspected for flaws. The next process is the pleating process, which starts with a roll of filter paper that is pleated via an automated filter paper pleating machine. The material then goes onto the slitting machine for proper slitting according to the specifications provided on the product drawing. The oil filter center tube is then added before the media assembly is completed. This involves placing the pleated filter paper onto the automatic paper splicing equipment. The thermosetting adhesive is then added before adding the end caps and baking in an oven. Next, the cap cover plate is placed in the tapping equipment and spot welded into place. The final assembly includes adding the O-rings, sealant, anti-drain valve, spring, and paper core into place. Then, all of the items are sealed, and a leak test is performed before final labeling and packaging. The applicable subheading for the oil filter (model WT505335) will be 8421.23.0000, 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: Oil or fuel filters for internal combustion engines. The general rate of duty will be 2.5 percent ad valorem. 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). Regarding the origin of the oil filter, it is our opinion that the manufacturing and assembly process performed in Malaysia is not considered complex. While numerous steps are needed to assemble the Chinese and Malaysian components, the core components, including the filter paper and metal articles (including the end caps and lower end cover assembly) are not transformed by the simple assembly process in Malaysia. The additional Malaysian components including the spray shell assembly, white powder, central tube, and labels are all minor components in comparison to the Chinese components and only complete the finished article. Therefore, in our opinion, the country of origin of the oil filter (model WT505335) is China, which is where the filter paper and metal articles (including the end caps and lower end cover assembly) are constructed. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition to subheading 8421.23.0000, HTSUS, listed above. Effective May 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobile parts. Additional duties on automobile parts of 25 percent are reflected in Chapter 99, heading 9903.94.05, as provided in subdivision (g) of U.S. note 33 to this subchapter. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.94.05, in addition to subheading 8421.23.0000, HTSUS, listed above. 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. At this time products of China, Hong Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. Your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.33, in addition to subheading 8421.23.0000, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8421.23.0000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading 9903.88.03 in addition to subheading 8421.23.0000, HTSUS, listed above. The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively. The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are

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). Regarding the origin of the oil filter, it is our opinion that the manufacturing and assembly process performed in Malaysia is not considered complex. While numerous steps are needed to assemble the Chinese and Malaysian components, the core components, including the filter paper and metal articles (including the end caps and lower end cover assembly) are not transformed by the simple assembly process in Malaysia. The additional Malaysian components including the spray shell assembly, white powder, central tube, and labels are all minor components in comparison to the Chinese components and only complete the finished article. Therefore, in our opinion, the country of origin of the oil filter (model WT505335) is China, which is where the filter paper and metal articles (including the end caps and lower end cover assembly) are constructed. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition to subheading 8421.23.0000, HTSUS, listed above. Effective May 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobile parts. Additional d