The country of origin of Refined Aluminum Hydroxide (dry)

N356703 December 29, 2025 OT:RR:NC:N3:136 CATEGORY: Origin Hiroshi Yokota Nippon Light Metal Company, Ltd. 1-1-13, Shimbashi, Minato-ku Tokyo 1058681 Japan RE: The country of origin of Refined Aluminum Hydroxide (dry) Dear Mr. Yokota: In your letter dated December 3, 2025, you requested a country of origin ruling on Refined Aluminum Hydroxide (dry). In your submission, you describe a scenario where crude wet aluminum hydroxide is imported from Brazil into your refinery in Japan. The crude wet aluminum hydroxide serves as the feedstock to produce smelter grade alumina, which is an intermediate raw material used to produce aluminum metal. This Brazilian aluminum hydroxide is a crude wet product that contains impurities, varies in particle size, and has a high content of sodium oxide, which makes it unsuitable for applications in advanced industries. In Japan you produce Refined Aluminum Hydroxide (dry), which you identify as SB93. The production process in Japan is described as follows: -The Brazilian crude wet aluminum hydroxide, Chemical Formula: Al(OH)3, CAS Number: 21645512, is made into a slurry for pipeline transportation (the sodium oxide level is lowered in this process). -Foreign materials are removed by filtration. -The slurry is dried into a powder to remove moisture. -Magnetic foreign materials are removed by magnet. -A sieve is used to remove coarse particles. During the refining process in Japan, foreign materials including magnetic ones are removed, the moisture content is lowered from 4.2% to 0.01%, the sodium oxide content is lowered from 0.28% to 0.26%, and the average particle size is lowered from 113um to 106um. You state that no chemical reaction occurs during the refining process. The finished product (SB93) is Refined Aluminum Hydroxide (dry), Al(OH)3, CAS Number: 21645512. This product will be imported into the United States and used as a heat dissipation filler for electric vehicles. 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). Regarding the country of origin of the Refined Aluminum Hydroxide (dry), it is our view that the crude wet aluminum hydroxide, sourced from Brazil, imparts the finished product’s essential character. The described refining process in Japan does not result in a substantial transformation of the crude wet aluminum hydroxide of Brazilian origin. Therefore, it is the opinion of this office that the country of origin of the Refined Aluminum Hydroxide (dry) is Brazil. 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 Nuccio Fera at nuccio.fera@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division