Country of origin of Dry Aluminum Hydroxide

N318586 April 22, 2021 MAR-2-28:OT:RR:NC:N3:136 CATEGORY: Origin Hiroshi Yokota Nippon Light Metal Company, Ltd. 1-1-13, Shimbashi, Minato-Ku Tokyo, 1058681 Japan RE: Country of origin of Dry Aluminum Hydroxide Dear Mr. Yokota: In your ruling request dated March 30, 2021, you requested a country of origin ruling on Dry Aluminum Hydroxide. In your ruling request, you state that Nippon Light Metal Company, Ltd. imports Wet Aluminum Hydroxide from Brazil into Japan to be further processed to produce Dry Aluminum Hydroxide, which will be imported into the United States. You have provided a production flowchart of the processing that occurs in Japan, which indicates the following: Starting material: Wet Aluminum hydroxide Repulping (slurry of Wet Aluminum Hydroxide and water) Filtration Drying Ending Material: Dry Aluminum Hydroxide 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 further processing in Japan of the imported product from Brazil, does not result in a substantial transformation of the Brazilian product. Therefore, in our opinion, the country of origin for the subject product is Brazil. 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