The country of origin of Giant Candy Canes In your letter dated January 8, 2025, you requested a country of origin ruling on giant candy canes. A manufacturing flowchart, list of product ingredients, spec. sheets and product samples accompanied your request. The product samples were disposed of. The subject merchandise is described as giant candy canes composed of white granulated sugar (product of Thailand), corn syrup (product of China), water, natural and artificial flavoring (product of China), titanium dioxide, and FD&C No. 40 (both are products of India). You have stated that all manufacturing is conducted in Cambodia. White granulated sugar, corn syrup and water are boiled, air is pumped out and the pot is cooled. Natural and artificial flavoring, titanium dioxide and FD&C Red No. 40 are added and blended evenly. The preparation is cooled and mixed (different colored sugar masses together) and the sugar stands are pulled into giant candy cane shapes. The giant candy canes will b

N344996 February 6, 2025 OT:RR:NC:N5:232 CATEGORY: Origin Joey Yu Kamyum Food (Cambodia) Co., Ltd. Ta Pov Village, Ta Nay Commune Prey Nub District Preah Sihanouk Province 180115 Cambodia RE: The country of origin of Giant Candy Canes In your letter dated January 8, 2025, you requested a country of origin ruling on giant candy canes. A manufacturing flowchart, list of product ingredients, spec. sheets and product samples accompanied your request. The product samples were disposed of. The subject merchandise is described as giant candy canes composed of white granulated sugar (product of Thailand), corn syrup (product of China), water, natural and artificial flavoring (product of China), titanium dioxide, and FD&C No. 40 (both are products of India). You have stated that all manufacturing is conducted in Cambodia. White granulated sugar, corn syrup and water are boiled, air is pumped out and the pot is cooled. Natural and artificial flavoring, titanium dioxide and FD&C Red No. 40 are added and blended evenly. The preparation is cooled and mixed (different colored sugar masses together) and the sugar stands are pulled into giant candy cane shapes. The giant candy canes will be packed into paper boxes, 1 giant candy canes per box, 4 boxes per master case. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). In this case, the mixture of ingredients results in a substantial transformation. The ingredients lost their separate identities and became an integral part of a new product. The country of origin of the giant candy canes is Cambodia. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Frank Troise at frank.l.troise@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division