The country of origin of a steering wheel cover.

N346802 April 3, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Irene Yuan Higher Technology (Cambodia) Co., Ltd. Land#189, Road 140, Bak Chenhchien Village, Trapeang Kong Commune, Samroang Tong District, Kampong Speu Province. Phnom Penh 050113 Cambodia RE: The country of origin of a steering wheel cover. Dear Ms. Yuan: In your letter dated March 17, 2025, you requested a country of origin ruling on a steering wheel cover. The product under consideration is a Steering Wheel Cover (Item Number 556358547), which is designed to fit over a standard automotive steering wheel. The steering wheel cover is made of faux leather with thermoplastic elastomer (TPE) inner, which provides grip and protection. The primary use of the steering wheel cover is to enhance the grip and provide a comfortable feel while driving, as well as to protect the steering wheel from wear and tear. It consists of a polyurethane (PU) and polyvinyl chloride (PVC) outer leather, PVC inner foam, and TPE inner ring. You state that the PVC powder, dioctyl phthalate (DOP), and dye for the outer leather is imported from China to Cambodia, where all the ingredients are mixed, foamed, shaped, rolled, pattern embossed, and extruded. The unplasticized PVC particles and powder from China are made into foam, cut, and put in rolls in Cambodia. The raw TPE plastic particles and DOP from China undergo injection and forming into an inner ring in Cambodia. In Cambodia, the outer leather and foam are then laminated to create a single PVC leather roll. The leather is cut to size, stitched, and sewn together with the inner ring. Finally, the product is inspected and packaged for import into the United States. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff?d, 989 F.2d 1201 (Fed. Cir. 1993). Based on the information supplied, the Chinese raw materials (particles and powder) undergo a significant change in Cambodia and are transformed into PVC leather material, foam, and the inner ring. Furthermore, the materials undergo a substantial transformation when integrated into a steering wheel cover in Cambodia. As a result, the country of origin of the steering wheel cover (Item Number 556358547) will be 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 Liana Alvarez at liana.alvarez@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division