The country of origin of Calcitriol Capsules in dosage form

N359283 March 26, 2026 OT:RR:NC:N3:138 CATEGORY: Origin Pei Zhang Epic Pharma LLC 227-15 North Conduit Avenue Laurelton, NY 11413 RE: The country of origin of Calcitriol Capsules in dosage form Dear Mr. Zhang: In your letter dated February 27, 2026, you requested a country of origin ruling on Calcitriol Capsules in dosage form. Calcitriol, imported in 0.25 mcg, and 0.5 mcg capsules, is a biologically active form of vitamin D. It is indicated for the management of secondary hyperparathyroidism and resultant metabolic bone disease in patients with moderate to severe chronic renal failure not yet on dialysis. It is also indicated for the management of hypocalcemia and its clinical manifestations in patients with postsurgical hypoparathyroidism, idiopathic hypoparathyroidism, and pseudohypoparathyroidism. In your letter, you stated that the active pharmaceutical ingredient (API), Calcitriol is manufactured in the Netherlands and that the finished capsules in dosage form is made in China. In China, the Calcitriol will be mixed with various inactive ingredients to produce the final Calcitriol Capsules in dosage form. 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 this case, we find the mixing of the active ingredient Calcitriol (made in the Netherlands) with the inactive ingredients into the final Calcitriol Capsules in dosage form in China does not result in a substantial transformation and the country of origin will be the Netherlands. This merchandise may be subject to the Federal Food, Drug, and Cosmetic Act and/or The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which are administered by the U.S. Food and Drug Administration (FDA). Information on the Federal Food, Drug, and Cosmetic Act, as well as The Bioterrorism Act, can be obtained by calling the FDA at 1-888-463-6332, or by visiting their website at www.fda.gov. 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 Judy Lee at judy.h.lee@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division