The country of origin of a soda-lime glass stone

N359546 March 26, 2026 OT:RR:NC:N1:126 CATEGORY: Origin Megan Zebrowski Kendra Scott 3800 North Lamar Suite 400 Austin, TX 78756 RE: The country of origin of a soda-lime glass stone Dear Ms. Zebrowski: In your letter dated March 7, 2026, you requested a country of origin ruling. The merchandise under consideration is identified as Material Number HS-45, described as a green soda-lime glass stone intended to emulate a cat’s eye gemstone, for use in jewelry. The finished article is a shaped, faceted, and polished glass stone. From the information you provided, a large block of soda-lime glass is manufactured in China by casting. The block measures approximately 360mm x 150mm x 35mm and is exported from China to Thailand for further processing. In Thailand, the Chinese origin glass block is cut into slices, which are then lapped to achieve the required thickness. The sliced material is subsequently sharpened into the final shape, faceted to create a gemstone-like appearance, and polished. The finished stones measure approximately 32.5mm x 15mm x 4mm. 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (CBP) Regulations (19 CFR 134) implements the country-of-origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. In this case, the processing performed in Thailand, including the cutting, lapping, shaping, faceting, and polishing, transforms the glass block from China into finished glass stones with a new name, character and use. Accordingly, the processing performed in Thailand constitutes a substantial transformation. Therefore, the country of origin of the finished glass stones will be Thailand. 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 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 Yani De Leon at yaniri.deleon@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division