The country of origin of Bar Soap

N347233 April 9, 2025 OT:RR:NC:N3:136 CATEGORY: Origin CJ Erickson Cowan Liebowitz & Latman 114 West 47th Street, 21st Floor New York, NY 10036 RE: The country of origin of Bar Soap Dear Mr. Erickson: In your letter dated March 31, 2025, on behalf of your client Dukal, LLC, you requested a country of origin ruling on Bar Soap. In your submission you describe a scenario where the subject Bar Soap is produced in China from soap noodles of Indonesia or Malaysian origin. In China the soap noodles are combined (manually mixed) with calcium carbonate and fragrance of Chinese origin. The mixing process does not result in a chemical reaction. The soap noodles comprise 70% of the content of the finished Bar Soap and 62% of the total value. You state that the calcium carbonate is merely a filler/texture ingredient, which does not alter the essential character of the soap noodles. The operations performed in China are limited to mixing, finishing, and packaging of the Bar Soap. 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). Regarding the Bar Soap’s country of origin, it is our view that the soap noodles impart the finished product’s essential identity, because they serve as the soap base and provide the primary ingredients of the finished Bar Soap. In China, the mixing, finishing, and packaging processes do not result in a substantial transformation of the soap noodles. Therefore, it is the opinion of this office that the country of origin of the Bar Soap is Indonesia or Malaysia depending on the origin of the soap noodles. 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 Nuccio Fera at nuccio.fera@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division