Country of origin of “TP5270 GREEN-LS Colorant”

N305556 August 28, 2019 MAR-2-32:OT:RR:NC:N3:136 CATEGORY: Origin Benjamin F. DeFazio B.F. DeFazio Customs Broker 99 W. Hawthorne Avenue, Suite 612 Valley Stream, NY 11570 RE: Country of origin of “TP5270 GREEN-LS Colorant” Dear Mr. DeFazio: In your ruling request dated August 1, 2019, on behalf of your client, Toyo Ink America, LLC, you requested a country of origin ruling on “TP5270 GREEN-LS Colorant.” You describe the product at issue as a colorant. This product is produced in Japan, incorporating various raw materials from China, Japan, and an unidentified country. You describe the materials used as pigment JZF-8375 from China, calcium stearate from Japan, and zinc stearate from an unidentified country. The provided manufacturing procedure flowchart shows that in Japan, crude pigment A (Intermediate 1) is combined with zinc stearate and calcium stearate via a kneading process, which you state, does not result in a chemical reaction. This initial process is followed by the processes of dispersing, milling, packaging, and inspection to produce the finished product, “Dry Color TP 5270 GREEN-LS,” which is a pigment based preparation. In 19 C.F.R. § 134.1(b), “country of origin” is defined as “the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the ‘country of origin’ within the meaning of this part.” With respect to “TP5270 GREEN-LS Colorant,” the production process in Japan using raw materials from China, Japan, and an unidentified country, does not result in a substantial transformation of the primary pigment material of Chinese origin. Therefore, in our opinion, the country of origin for the subject product is China. This merchandise may be subject to the requirements of the Toxic Substances Control Act (TSCA), which are administered by the U.S. Environmental Protection Agency. Information on the TSCA can be obtained by contacting the EPA at 1200 Pennsylvania Avenue, N.W., Mail Code 70480, Washington, D.C., by telephone at (202) 554-1404, or by visiting their website at www.epa.gov. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Nuccio Fera at nuccio.fera@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division