The country of origin of a plastic bucket

N354086 October 17, 2025 OT:RR:NC:N4:422 CATEGORY: Origin Ms. Lincy Tang Nature's Mark 9999 Bellair Blvd., Suite 908 Houston, TX 77036 RE: The country of origin of a plastic bucket Dear Ms. Tang: In your letter dated September 23, 2025, you requested a country of origin ruling on a plastic bucket on behalf of your client, Walgreens Co. Photographs and a manufacturing process chart were submitted for our review. The merchandise under consideration is the Hello Kitty and Friends plastic bucket, WIC#638269. The round pink bucket is primarily made of polypropylene plastic. It contains an open top with a flat bottom and a plastic carrying handle. The article measures approximately 8.5 inches in diameter and is 7 inches high. The exterior of the bucket features colored Easter eggs and six licensed Sanrio characters: Hello Kitty, Kuromi, My Melody, Cinnamoroll, Little Twin Stars, and Pompompurin. Each of the characters is dressed as an Easter bunny. The bucket is not food safe and is intended for ages 3 and up. In your letter, you indicated that all parts are sourced from China and Cambodia as follows: Components of Chinese Origin PP-H (polypropylene homopolymer) Plastic material PE (Polyethylene) Plastic material UPC (Universal Product Code) Label Components of Cambodian Origin Printing ink Paper Carton All the assembly and manufacturing processes, including testing and inspection, are performed in Cambodia: injection (bucket and handle), printing (heat transfer to print the pattern onto the bucket), assembly (the handle to the top of the bucket and stick the UPC label on the bottom), and packaging (paper and carton). When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter 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 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 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” within the meaning of the marking laws and regulations. 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). This office reviewed the provided assembly process information and is of the opinion that the Chinese and the Cambodian components undergo processing in Cambodia, which results in a substantial transformation. These components lose their individual identities and become an integral part of a new article, possessing a new name, character, and use. Accordingly, from the details submitted, the country of origin for the plastic bucket would 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 Dana L. Giammanco at dana.l.giammanco@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division