The country of origin of two foam mattresses incorporated into a sleeper sofa bed

N348576 May 20, 2025 OT:RR:NC:N4:463 CATEGORY: Country of Origin Robert D. Stang Husch Blackwell LLP 1801 Pennsylvania Ave. NW, Ste. 1000 Washington, DC 20006 RE: The country of origin of two foam mattresses incorporated into a sleeper sofa bed Dear Mr. Stang: In your letter dated May 4, 2025, you requested a country of origin ruling on behalf of your client, Synergy Home Furnishings LLC, for two memory foam mattresses. In lieu of samples, pictures and product descriptions were provided. Item 1 is identified as the One Step 4.75" Foam Mattress, item number SF. The mattress measures 76" (L) x 4.75" (H) x 52" (W). The non-slip outer cover is made of 300 gsm 64% polyester/36% rayon knit fabric and has a zipper closure. Item 2 is identified as the Standard Mech Sleeper 4.5" Foam Mattress, item number VF. The mattress measures 75" (L) x 4.5" (H) x 52" (W). The non-slip outer cover is made of 270 gsm, 100% polyester knit fabric and has a zipper closure. The literature states that the following operations are performed in Japan: 100% polyurethane memory foam is extruded, layered, cut to size, sewn into a fireproof sock and zipped into an outer cover to produce a finished mattress. The finished mattress is wrapped in plastic, compressed by rolling, and shipped to Cambodia. In Cambodia, the mattress is unrolled and allowed to decompress and then placed on a metal frame inside a Cambodian-origin sofa bed. No other operations are performed on the mattress, and it is not attached or otherwise secured. The sleeper sofa bed with the incorporated mattress is packed for export and shipped to the United States. COUNTRY OF ORIGIN 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). Section 134.1(b), Customs Regulations (19 C.F.R. ? 134.1(b)), defines ?country of origin? 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. ? A substantial transformation occurs when articles lose their identity and become articles having a new name, character, or use. No one factor is decisive. Per the information provided, the Japanese-origin mattresses, subject of this ruling, are incorporated into Cambodian-origin sleeper sofas in Cambodia. ?No operations other than the mere placement of the mattresses on the sleeper frame are performed in Cambodia. ?As such, although subsumed in the Cambodian-origin sleeper sofas, the Japanese-origin mattresses have not lost their own identity. ?They have not undergone a substantial transformation, they have not taken on a new name, character or use, and they retain their identity as mattresses and, therefore, they maintain their Japanese country of origin. ?(See NYRLs N339107, N315271, N322850, and Headquarters Ruling Letter H318891.) In view of these facts, the country of origin of item 1, the One Step 4.75" Foam Mattress with item number SF, and item 2, the Standard Mech Sleeper 4.5" Foam Mattress with item number VF, is Japan. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is 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. If the facts are modified in any way, or if the goods do not conform to these facts at the time of importation, you should bring this to the attention of 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 Title 19 of the Code of Federal Regulations (19 C.F.R. Part 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 Seth Mazze at seth.mazze@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division