The country of origin of limestone tile.

N359698 April 7, 2026 OT:RR:NC:N1:128 CATEGORY: Origin Ms. Katherine A. Dobscha Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP 599 Lexington Avenue New York, NY 10022 RE: The country of origin of limestone tile. Dear Ms. Dobscha: In your letter dated March 12, 2026, you requested a country of origin ruling on behalf of your client, Artistic Tile Inc., for item number SRAVMOCA1224, which is part of the Ravine Moca Limestone tile collection. From the information you provided, limestone blocks are quarried in Portugal. The blocks are sawn into smaller pieces and then cut into smooth-surfaced tiles which measure 12 inches long by 24 inches wide and are between 0.7 inches and 0.8 inches in thickness. These tiles are then exported to India. In India, the surface of the tile is honed, resulting in a rough, corrugated surface with horizontal grooves running the length of the tile. The tiles retain their length and width but are now 0.375 inches thick at the grooves and 0.625 inches thick at the projections. The finished tiles are then exported to the United States for installation as wall coverings. 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). The SRAVMOCA1224 tiles are cut to size and shape in Portugal and are identifiable as tiles upon importation into India. They remain identifiable as tiles after they are surface-worked in India. Thus, the processing which takes place in India does not render the tiles into a new and different article. The country of origin of the SRAVMOCA1224 tiles is Portugal. 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 Nicole Sullivan at nicole.d.sullivan@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division