The classification, marking, and eligibility under the United States-Mexico-Canada Agreement (USMCA) of suitcases.

N362599 July 22, 2026 OT:RR:NC:N4:441 CATEGORY: Origin Sarah Raymond GDLSK 599 Lexington Ave, Floor 36 New York, NY 10022-6030 RE: The classification, marking, and eligibility under the United States-Mexico-Canada Agreement (USMCA) of suitcases. Dear Ms. Raymond: In your letter dated June 25, 2026, you requested a country of origin marking and USMCA determination on behalf of your client, Nysonian Inc. The articles at issue, model number NOBL AIO 3.0, are molded plastic rolling suitcases that are structured and rigid on all sides. They are available in two sizes: carry-on and checked bag. You have indicated in your submission that the parts, materials, and components will be imported under four scenarios as outlined below. Manufacturing Steps The NOBL suitcases are comprised of a front shell, middle shell, back shell, aluminum frame, telescopic pull rod, top handle, side handle, four wheels, two TSA locks, various textile components such as the lining and pockets, and numerous screws, rivets, washers, and other fasteners. They will be assembled in Mexico with Chinese components under four scenarios as follows: Scenario 1 Plastic shells are extruded and formed in Mexico from Mexican-origin polycarbonate resin. The textile components (binding webbing, computer bag lining, front mesh pocket lining, lining of the middle and back shell, and missile mesh lining) are cut and sewn in Mexico from either Mexican fabric or foreign fabric. All other materials are of Chinese origin. All other processes and assembly steps are performed in Mexico. Scenario 2 Plastic shells are extruded and formed in Mexico from Mexican-origin polycarbonate resin. All other components are Chinese origin, aside from packaging. All other processes and assembly steps are performed in Mexico. Scenario 3 Chinese origin polycarbonate resin is extruded; the plastic shells are formed in Mexico. All other components are Chinese origin, aside from the packaging. All other processes and assembly steps are performed in Mexico. Scenario 4 Chinese origin polycarbonate resin is extruded; the plastic shells are formed in China and sent to Mexico for further processing. All other components are Chinese origin, aside from the packaging. All other processes and assembly steps are performed in Mexico. CLASSIFICATION The applicable subheading for the molded plastic suitcases will be 4202.12.2120, Harmonized Tariff Schedule of the United States (HTSUS), which provides for trunks, suitcases, and similar containers: with outer surface of plastics: structured, rigid on all sides. The general rate of duty will be 20 percent ad valorem. USMCA The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note ("GN") 11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a “good originating in the territory of a USMCA country” only if 1. the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; 2. the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; 3. the good is a good produced entirely in the territory of one or more USMCA countries using non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o)); Since the Chinese origin materials are non-originating, the suitcases which contain these components are not considered goods wholly obtained or produced entirely in a USMCA country under GN 11(b)(i), nor are the products produced exclusively from originating materials per GN 11(b)(ii). Thus, we must determine whether the products qualify under GN 11(b)(iii). As stated above, the applicable subheading for the molded plastic suitcases is 4202.12.2120, HTSUS. The applicable rule of origin for goods classified under these subheadings is in GN 11(o), which provides in relevant part: 3. A change to subheading 4202.12 from any other chapter, except from headings 5407, 5408 or 5512 through 5516, or fabric of man-made fibers of subheading 5903.10, fabric of man-made fibers of subheading 5903.20, fabric of man-made fibers of subheading 5903.90, fabric of man-made fibers of subheading 5906.99 or fabric of man-made fibers of subheading 5907.00. You have indicated in your submission that all the components are classified outside of Chapter 42, headings 5407, 5408 or 5512 through 5516, subheadings 5903.20, 5903.90, 5906.99, and 5907.00. As such, based on the information provided, the suitcases in scenarios 1-4 meet the tariff shift requirement and are eligible for preferential tariff treatment under the USMCA. COUNTRY OF ORIGIN MARKING 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). 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. Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in sections 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining the country of origin of a good for marking purposes, with the exception of textile and apparel goods which are subject to the provisions of 19 CFR 102.21. See 19 CFR 102.11. Applied in sequential order, 19 CFR 102.11(a) provides that the country of origin of a good is the country in which: (1) The good is wholly obtained or produced; (2) The good is produced exclusively from domestic materials; or (3) Each foreign material incorporated in that good undergoes an applicable change in tariff classification set out in Part 102.20 and satisfies any other applicable requirements of that section, and all other applicable requirements of these rules are satisfied. The suitcases are neither “wholly obtained or produced” nor “produced exclusively from domestic materials.” Therefore, paragraphs (a)(1) and (a)(2) cannot be used to determine the country of origin of the suitcases, and paragraph (a)(3) must be applied next to determine the origin of the finished articles. As stated above, the suitcases are classified under subheading 4202.12, HTSUS. The tariff shift requirement in Part 102.20 for the suitcases at issue states: A change to subheading 4202.12 through 4202.22 from any other heading, provided that the change does not result from the assembly of foreign cut components. Based on the information provided, all components are classified in headings other than 4202. Scenario 1 meets the tariff shift rule and, as such, the country of origin for marking purposes is Mexico. However, in scenarios 2 and 3, the production includes assembly of foreign cut components. As such, scenarios 2 and 3 do not meet the tariff shift requirement. As the production in Mexico also includes the extrusion of the plastic shells, section 102.11(b) does not apply. Where the country of origin of a good cannot be determined under paragraph (a), (b) or (c) of this section, the country of origin of the good shall be determined as follows: (1) If the good was produced only as a result of minor processing, the country of origin of the good is the country or countries of origin of each material that merits equal consideration for determining the essential character of the good; (2) If the good was produced by simple assembly and the assembled parts that merit equal consideration for determining the essential character of the good are from the same country, the country of origin of the good is the country of origin of those parts; or (3) If the country of origin of the good cannot be determined under paragraph (d)(1) or (d)(2) of this section, the country of origin of the good is the last country in which the good underwent production. The country of origin of the suitcases manufactured under scenarios 2-3 cannot be determined using the marking rules set forth under 19 C.F.R. §102.11(c), (d)(1) or (d)(2). As noted above, scenarios 2-3 do not meet the requirement of the tariff shift rules of 19 C.F.R. §102.20 for merchandise of subheading 4202.12, HTSUS, because the suitcases were assembled from foreign cut components. In addition, there is no single material that imparts the essential character of the suitcases. Finally, the suitcases will not be produced using “minor processing” or “simple assembly.” Consequently, the country of origin for marking purposes would be the last country in which the subject suitcases (scenarios 2-3) undergo production, which is Mexico. See 19 C.F.R. §102.11(d)(3). Regarding scenario 4, the tariff shift requirement in Part 102.20 is not met because the plastic shells and all other components are already formed/cut in China. The next rule to be applied is 19 C.F.R. § 102.11(b)(1), which requires a determination as to the single material that imparts the essential character of the good. “Material” is defined in 19 C.F.R. § 102.1(m) as “a good that is incorporated into another good as a result of production with respect to that other good, and includes parts, ingredients, subassemblies, and components.” Section 102.18(b)(1)(iii) provides that if there is only one material that is classified in a tariff provision from which a change in tariff classification is not allowed, then that material will represent the single material that imparts the essential character to the good under 19 C.F.R. § 102.11(b)(1). Since the only materials here are the Chinese components, the country of origin for marking purposes under scenario 4 is China. SUBSTANTIAL TRANSFORMATION 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 (HQ) 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). The subject merchandise emerges as a product with a new name, character and use when the polycarbonate resin is extruded and formed into the molded plastic shells. As such, under the manufacturing scenarios 1-3, a substantial transformation occurs in Mexico. Under scenario 4, the substantial transformation occurs in China. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 Vikki Lazaro at vikki.lazaro@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division