The country of origin of CR39 or polycarbonate sheets

N355563 December 3, 2025 OT:RR:NC:N5:137 CATEGORY: Origin Peter Quinter Gunster, Yoakley & Stewart, P.A. 600 Brickell Ave., Suite 3500 Miami, FL 33131 RE: The country of origin of CR39 or polycarbonate sheets Dear Mr. Quinter: In your letter dated October 31, 2025, you requested a country of origin ruling on sheets of CR39 or polycarbonate. The product under consideration is noted to be safety plates composed of CR39 or polycarbonate. The plates are rectangular in shape, measuring either 2 inches by 4 inches or 4 inches by 5 inches. The plates have not been optically worked in any way. They will be incorporated into welding helmets to protect the eyes from projectiles. In your request, you suggest classification of the safety plates in heading 9001, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. Heading 9001, HTSUS, covers various articles that are considered optically worked. Additional U.S. Note 1 to Chapter 90 defines the term optically worked as an article “the surface of which has been ground or polished in order to produce the required optical effect.” Per the information provided, the subject plastic sheets are not worked in this way and do not provide any optical effect to the end user. As such, classification under heading 9001, HTSUS, in not applicable. When determining the country of origin for purposes of applying current trade remedies under Section 301and 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). Flat sheets or rolls of bulk plastic with a scratch resistant film are manufactured in China in thicknesses of 1 mm or 1.5 mm. The Chinese origin sheet or rolls are shipped to India. In India, a saw is used to cut the bulk sheets into small rectangles of either 2 inches by 4 inches or 4 inches by 5 inches. The edges are deburred, the sheets are embossed with the applicable safety rating, and the scratch resistant film is removed. The small rectangular sheets are packaged into individual printed plastic sleeves or bags. It is the opinion of this office that the cutting to size, deburring and embossing of the plastic sheet in India does not result in a substantial transformation. Therefore, the country of origin of the CR39 or polycarbonate sheets will remain China. 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 Christina Allen at julie.c.allen@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division