The country of origin of worked abalone shells.

N358060 February 11, 2026 OT:RR:NC:N4:415 CATEGORY: Origin Megan M. Zebrowski Kendra Scott 3800 North Lamar Boulevard, Suite 400 Austin, Texas 75077 RE: The country of origin of worked abalone shells. Dear Ms. Zebrowski: In your letter dated January 21, 2026, you requested a country of origin ruling. Images were provided in lieu of a sample. The product under consideration is described as abalone color bar shell stones, style number 10016. Your submission indicates the abalone shells are sourced from China and then shipped to your factory in Thailand. Once in Thailand, the factory cuts the shells into slices. These slices are then lapped to achieve the appropriate thickness of the finished article. It will then be sharpened, which shapes the sliced and lapped material into its final form. In this scenario, this will be your “Danielle” shape. After being shaped, the shell is ground to achieve a flat surface and then finally it will be polished. 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). In order to determine whether a substantial transformation occurs when components are assembled into completed products, all factors such as the components used to create the product and manufacturing processes that these components undergo are considered in order to determine whether a product with a new name, character, and use has been produced. No one factor is decisive, and assembly/manufacturing operations that are minimal will generally not result in a substantial transformation. This office holds the opinion that the raw shells have a predetermined end use, have the basic nature of the finished worked shells, and that they are not substantially transformed to become a new article having a new name, character, or use after being further processed in Thailand. Accordingly, the country of origin for these abalone color bar shell stones, style number 10016, will be 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 CBP Regulations (19 CFR 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, contact National Import Specialist Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division