The country of origin of Animal Feed Premix

N355838 November 20, 2025 OT:RR:NC:N5:231 CATEGORY: Origin Mr. Robert Kossick Olsson Frank Weeda Terman Matz PC 2000 Pennsylvania Avenue, NW Washington, DC 20006 RE: The country of origin of Animal Feed Premix Dear Mr. Kossick: In your letter dated November 7, 2025, you requested a country of origin ruling on an animal food premix on behalf of your client, Jefo Nutrition Inc. (Saint-Hyacinthe, Québec, Canada). The subject merchandise is ValmoCare MEGAA® premix for animal feed. It is produced in Canada by blending three components: guanidinoacetic acid (“GAA”) (79 percent) sourced from China, DL-methionine (“DLM”) (20 percent) from the United States, and corn starch (1 percent) from China. The combination of GAA and DLM is described as facilitating a biosynthetic interaction in which methionine enables the conversion of GAA into creatine within poultry. Manufacturing operations in Canada include the receipt of the imported GAA, DLM, and corn starch; verification of raw material quality against certificates of analyses; weighing according to formulation; and dry blending under controlled processing conditions. The resulting product, a non-toxic and non-hazardous animal feed premix marketed as ValmoCare MEGAA®, is packaged in bulk totes, labeled with lot identification, and stored in a warehouse pending export to the United States. You seek a determination as to the country of origin of the above-described product. 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). In this case, the processing performed in Canada does not constitute a substantial transformation. The Canadian operations consist only of drying and blending the ingredients, and the resulting product does not emerge as a new or distinct article. Accordingly, the animal feed premix keeps the origin of its ingredients and is considered a product of both China and the United States. 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). This merchandise is subject to The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which is regulated by the Food and Drug Administration (FDA). Information on the Bioterrorism Act can be obtained by calling the FDA at 301-575-0156, or at the Web site www.fda.gov/oc/bioterrorism/bioact.html. 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 Ekeng Manczuk at ekeng.b.manczuk@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division