Country of origin of “Lionel Blue RF-42704 Pigment”

N306537 November 8, 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 11580 RE: Country of origin of “Lionel Blue RF-42704 Pigment” Dear Mr. DeFazio: In your ruling request dated October 2, 2019, on behalf of your client, Toyo Ink America, LLC, you requested a country of origin ruling on “Lionel Blue RF-42704 Pigment.” You describe the subject product as a colorant, which is produced in Japan, incorporating various raw materials from China and Japan. You describe the raw materials from China as Phthalocyanine Crude A (Key Raw Material, 16.05% of product composition), Phthalocyanine Crude B (Key Raw Material, 0.14% of product composition), and Rosin Acid Salt (Subsidiary Raw Material, less than 5.62% of product composition). You describe the various raw materials from Japan as Subsidiary Raw Materials (78.19%-83.80% of product composition). The production process in Japan consists of the following steps: Pigmentation of Intermediate 1 with Crude A (No Chemical Reaction) Pigmentation of Intermediate 2 with Crude A (No Chemical Reaction) Synthesis of Intermediate 3 with Crude B and Pigmentation from Crude A, resulting in a Chemical Reaction with Chloro-sulfonation and Amination Mixing with Nauter Mixer Milling (Hammer Mill). Inspection and Storage 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 the subject product, we have determined that the production process in Japan using raw materials from China and Japan, does not result in a substantial transformation of the key raw materials 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 (EPA).  Information on the TSCA can be obtained by contacting the EPA at Document Control Office (7407M), Office of Pollution Prevention and Toxics (OPPT), Environmental Protection Agency, 1200 Pennsylvania Avenue, N.W., Washington, D.C., 20460, by calling the Toxic Substances Control Act Hotline at (202) 554-1404, by e-mailing to tsca-hotline@epa.gov, 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