The country of origin of pigments

N359464 March 26, 2026 OT:RR:NC:N3:136 CATEGORY: Origin Bernd Strobel Heubach Colorants Germany GmbH Brüningstr 50 Frankfurt 65292 Germany RE: The country of origin of pigments Dear Mr. Strobel: In your letter dated March 5, 2026, you requested a country of origin ruling on pigments. In your submission, you describe a scenario where a pigment produced in India will be sent to Mexico to be b lended with a pigment produced in Mexico in a dry blending step. No additional grinding or wet mixing takes place. The final product, consisting of 49% Indian pigment and 51% Mexican pigment, will be exported from Mexico to the United States. The pigment produced in India is described as Dalamar Yellow YT 800D-IN, SAP 252521, also known as Pigment Yellow 065 (CAS 6528-34-3). This product consists of Fast Bordo GP Base (CAS 96-96-8), Acetoacet-o-anisidide (CAS 92-15-9), and non-reactive additives. The pigment produced in Mexico is described as Dalamar Yellow YT 800D-MX, SAP 161659, also known as Pigment Yellow 065 (CAS 6528-34-3). This product consists of Fast Bordo GP Base (CAS 96-96-8), Acetoacet-o-anisidide (CAS 92-15-9), and non-reactive additives. These pigments are bright reddish, have very good weather fastness, and high opacity in applications. 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 final product, it is our view that the Indian and Mexican sourced pigments do not undergoes a substantial transformation during the blending process in Mexico. The described blending of materials does not result in a chemical reaction or substantial change of the sourced pigments. Therefore, it is the opinion of this office that the country of origin of the blended finished product is India and Mexico. 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) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division