CBP Proposes to Revoke Ruling on Origin of Air Conditioners

In the Sept. 9, 2026, Customs Bulletin and Decisions, U.S. Customs and Border Protection is proposing to revoke ruling NY N352477 regarding the country of origin of outdoor split air conditioning units. Comments on this proposed change are due by Oct. 9.

The units at issue consist of a chassis that encloses a compressor, a condenser, a motor, a fan, a printed circuit board, and valves. Each unit is designed to be paired with a separately imported indoor unit to produce a system that heats and cools spaces. The final assembly of each unit occurs in Thailand using components from China and subassemblies produced in Thailand.

In ruling NY N352477 CBP determined that the components from China were not substantially transformed during the final assembly process in Thailand and that the country of origin of the outdoor units was therefore China. CBP explained that the steps that occur during the final assembly process are not complex, as they consist of processes such as screwing, bolting and welding.

However, CBP now finds that the operations performed in Thailand do substantially transform the foreign components. These operations include the fabrication of fan assemblies using plastic injection molding, production of the PCB assembly, fabrication of sheet metal into components, production of the condenser from Thai or Chinese copper and aluminum, mounting the Chinese-origin compressor to the chassis, and final assembly of the units.

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