In ruling NY N308736, Customs and Border Protection (CBP) determined the country of origin of a Keurig Model K90 single serve coffee brewer. This coffee brewer measures approximately 13 inches tall, by 10 inches wide, and 13 inches deep. It includes features such as choice of cup size, auto-off functionality, and a removable drip tray.

The coffee brewer will be exported to the United States from Indonesia. The manufacturing and assembling of various subassemblies would be undertaken in Malaysia and Indonesia, with final assembly in Indonesia. The brewer consists of two principal components, the hot water tank and the brewer base, and three supporting subassemblies, the cold water tank, the user interface, and the puncture mechanism. In addition, it consists of various tubes for the conveyance of water between the subassemblies, connecting electrical wires, and a power cord.

The hot water tank and brewer base assembly would be manufactured and assembled in Malaysia and would then be sent to Indonesia and incorporated with the other subassemblies into the completed brewer. The hot water heater subassembly would use parts sourced from Malaysia, China, and a third country, with the bulk coming from China. The brewer base subassembly would be assembled from parts sourced from Malaysia, Vietnam, and China.

CBP determined that the hot water tank subassembly is what provides the essential character to this product and allows it to be classified under heading 8516. As the parts of various origin are substantially transformed into the completed hot water tank and brewer base subassemblies, these components would be Malaysian in origin. The additional steps completed in Indonesia, described as “screw driver operations,” are considered by CBP to be simple assembly and does not substantially change the nature of this product. Therefore, CBP determined that the Model K90 single serve coffee brewer would be a product of Malaysia.