Request for Reconsideration of NY N360536; Country of Origin of Mirka Iridium SR PSA and Mirka Iridium SR Grip

H360070 June 18, 2026 OT:RR:CTF:VS H360070 AP CATEGORY: Origin Elina Maria Högkulla Project Manager Mirka Ltd. Pensalavagen 210 Jeppo 66850 Finland RE: Request for Reconsideration of NY N360536; Country of Origin of Mirka Iridium SR PSA and Mirka Iridium SR Grip Dear Ms. Högkulla: This is in response to your request dated April 16, 2026, on behalf of the exporter Mirka Ltd., requesting reconsideration of New York (“NY”) ruling N360536, dated April 15, 2026. We have reviewed your request and affirm NY N360536. NY N360536 describes the subject merchandise as follows: The merchandise at issue is described as the Mirka Iridium SR PSA and Mirka Iridium SR Grip. They are abrasive discs designed to be affixed to tools in order to sand epoxy, acrylic, and other resin-based surfaces on road, aerospace, rail, and marine vehicles. From the information you provided, the manufacturing process of the Mirka Iridium SR PSA is as follows: the “Jumbo J1 roll,” which consists of artificial silicon carbide abrasive grains affixed to a PET film backing, is imported into Finland from China. A roll of “release paper” is imported into Finland from Italy. In Finland, a pressure-sensitive adhesive is applied to the back of the Jumbo J1 roll. The Jumbo J1 roll is then laminated onto the release paper. This material is laser-cut, resulting in multiple individual discs on the uncut roll of release paper. In use, the discs are peeled off the release paper and affixed to tools using the pressure-sensitive adhesive. For the Mirka Iridium SR Grip, the Jumbo J1 roll is imported into Finland from China. “Grip fabric,” which has a hook-and-loop backing, is imported into Finland 2 from Italy. In Finland, the Jumbo J1 roll is laminated to the grip fabric. This material is then laser-cut into separate, individual discs. In use, the discs are affixed to tools using the hook-and-loop backing. NY N360536 concluded that the Jumbo J1 roll manufactured in China was identifiable upon importation into Finland as abrasive grain affixed to a Polyethylene Terephthalate (“PET”) film backing. While the processing in Finland enhances the functionality of the abrasive grain material, it does not change its fundamental name, character or use, and does not constitute substantial transformation. In your request for reconsideration, you state that the Jumbo J1 roll is not a finished Iridium SR product and is one of several components required for the manufacture of the final Iridium SR products. You also state that the materials are transformed into finished abrasive discs after they are laminated together and cut into individual discs. You assert that the processes in Finland add substantial value and improve performance and usability. A substantial transformation occurs “when as a result of a process an article emerges, having a distinctive name, character or use” from the original material subjected to the process. Belcrest Linens v. United States, 741 F.2d 1368, 1372 (Fed. Cir. 1984). If the manufacturing process is a minor one, which leaves the identity of the imported article intact, a substantial transformation has not occurred. See Uniroyal, Inc. v. United States, 3 CIT 220, 542 F. Supp. 1026 (1982), aff’d per curiam, 702 F.2d 1022 (Fed. Cir. 1983). U.S. Customs and Border Protection (“CBP”) looks at the totality of the circumstances and makes decisions on substantial transformation on a case-by-case basis. The country of origin of the article’s components, the extent of the processing that occurs within a given country, and whether such processing renders a product with a new name, character, and use are primary considerations. NY N326241, dated June 14, 2022 involved abrasive discs designed for use with orbital sanders. In South Korea, abrasive grains were affixed to a polyester film base using adhesive. The resulting material was baked, coated with resin and a stearate coating, rolled up, and shipped to China. In China, a hook-and-loop backing was laminated onto the rolls, and the laminated rolls were die-cut into specific sizes and hole patterns. CBP concluded that the processing in China, which was similar to the processing taking place in Finland, did not result in a new product with a distinctive name, character or use. The country of origin of the abrasive discs was South Korea. Similarly, in NY L86542, dated October 31, 2005, the surface conditioning material (textile material coated with abrasive grain) of abrasive discs was manufactured in Italy. The conditioning material was cut and placed on metal or plastic disc retainers in China. The country of origin of the abrasive discs was Italy, the country of origin of the surface conditioning material. Further, in Headquarters Ruling (“HQ”) H306091, dated Feb. 18, 2020, jumbo rolls from multiple countries were unspoiled, chemical primer and glue were applied to the back side of the paper, and chemical release coating was applied to the front. The paper was re-rolled, cut into large sheets, which were jogged and collated, and then cut into smaller units by a large guillotine cutter. The final product was essentially a smaller size paper with chemical release coating applied to the front, and chemical primer and glue on the back that was not transformed into a 3 new separate article of commerce. The origin of the jumbo paper roll dictated the origin of the sticky notes. In HQ 563306, dated Sept. 20, 2005, jumbo rolls of tissue paper that were cut, folded and packaged into gift tissue paper were not substantially transformed because the jumbo rolls did not have a different use or character than the finished packaged tissue paper. The processing was considered “mere finishing operations.” In NY N307942, dated Dec. 19, 2019, bulk rolls of tissue paper printed with a design were not substantially transformed as a result of being hot-stamped with foil film, cut to size, and folded. Also, in NY N337541, dated May 7, 2024, the process of adding aerogel slurry to mica components in South Korea followed by lamination, drying, and cutting did not substantially transform the mica components into a thermal insulation sheet. The reconstructed mica components were identifiable as articles of mica, which had natural electrical and thermal insulating properties and enhanced the structural stability of the sheet. The country of origin of the thermal insulation sheet was China where the reconstituted mica components were manufactured. As in the above-cited cases, the processing in Finland is a finishing operation and does not transform the abrasive grain material into a new product having a distinct name, character, or use. For the Mirka Iridium SR PSA, a pressure-sensitive adhesive is applied to the back of the Jumbo J1 roll in Finland, and the Jumbo J1 roll is laminated onto release paper and is laser-cut into individual discs. For the Mirka Iridium SR Grip, the Jumbo J1 roll is laminated to the grip fabric in Finland, and the resulting material is laser-cut into individual discs. Therefore, the country of origin of the abrasive grain material dictates the country of origin of the abrasive discs. For all of the aforementioned reasons, we find that the Mirka Iridium SR PSA and Mirka Iridium SR Grip are products of China, the country of origin of the Jumbo J1 rolls, and that NY N360536 correctly determined the country of origin of the abrasive discs. We therefore affirm NY N360536, dated April 15, 2026. Sincerely, Monika R. Brenner, Chief Valuation and Special Programs Branch