The country of origin of disposable nitrile rubber gloves

N354627 October 30, 2025 OT:RR:NC:N3:354 CATEGORY: Origin Mr. Raymond Cuthbert PT Basic International Sumatera Jalan Surfaktan Kavling D09-D16, C8-C15, C16 (Setengah) - C24, Kawasan Ekonomi Khusus Rt. 000 Rw. 000, Sei Mangkei, Bosar Maligas, Kab. Simalungun, Sumatera Utara 21183 Indonesia RE: The country of origin of disposable nitrile rubber gloves Dear Mr. Cuthbert: In your letter dated October 5, 2025, you requested a country of origin ruling on disposable nitrile rubber gloves. A description of the manufacturing process and pictures of the products accompanied your letter. You outline scenarios where gloves are manufactured by utilizing hand molds to create the glove through a dipping process. There are two production scenarios, Specification A and Specification B. Specification A allows for raw materials of: LG latex and Synthomer latex originating in Malaysia. Kumho latex originating in Korea. Titanium dioxide, zinc oxide, sulfur, accelerator BZ, blue pigment paste, antioxidant, purple pigment paste, accelerator EZ, and other auxiliary chemicals originating in China, Indonesia, Malaysia and other countries. Specification B allows for raw materials of: LG latex, Synthomer latex and other latex originating in Malaysia. Titanium dioxide, zinc oxide, sulfur, accelerator BZ, blue pigment paste, antioxidant, purple pigment paste, accelerator EZ, and other auxiliary chemicals originating in China, Indonesia, Malaysia and other countries. The production processes that take place in Indonesia are the same for Specifications A and B and are as follows: 1. 1. Cleaning - Hand molds are cleaned in acid wash tanks, water rinse tanks, roller brushes, and alkaline wash tanks to remove residual release agents, oils, and impurities, ensuring a clean surface for subsequent dipping. 2. Dipping - The cleaned molds are immersed in coagulant tanks, followed by sequential dipping in latex tank 1 and latex tank 2. The coated molds then pass through coagulant ovens, latex oven 1, and latex oven 2, allowing the latex to evenly adhere and preliminarily form the glove shape through coagulation and drying. 3. Vulcanization - The preliminarily formed gloves on molds are processed in dehumidification ovens and main vulcanization ovens, where crosslinking reactions occur to achieve strength, elasticity, and durability. 4. Aging - vulcanized gloves undergo cooling in cooling tanks, chlorination in chlorination tanks, neutralization in neutralization tanks, post-drip filtration in filtration tanks, silicone oil application in silicone oil tanks, and final baking in finishing ovens to enhance donning properties and surface smoothness. 5. Stripping and Inspection - gloves are stripped from the molds using a stripping machine, followed by visual inspection and automated counting. 6. Packaging - the inspected gloves are boxed, packed into cartons, and palletized for shipment. 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). The manufacturing operations that occur in Indonesia transform raw material components (liquid latex rubber and chemicals) into a fully functional glove. None of these raw materials can function alone as a protective hand covering but the finished item is a new and different article that can function alone as a protective hand covering, i.e., a glove. Therefore, the country of origin of the gloves is the country where the gloves are manufactured from the component materials. The country of origin of the gloves for Specifications A and B is Indonesia. 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 Karen Sikorski at karen.sikorski@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division