RE: The country of origin of leather from Brazil

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365756 October 19, 2026 CLA-2:OT:RR:NC:N3:34 CATEGORY: Origin Linda Singh Savino Del Bene 230-59 International Airport Center Blvd, Suite 260 – North Lobby Springfield Gardens, NY 11413 RE: The country of origin of leather from Brazil Dear Ms. Singh: In your letter dated October 5, 2026, you requested a country of origin ruling for leather hides on behalf of RMG Leather USA LLC DBA Carroll Leather. The manufacturing process and a sample was provided for review. The bovine leather hides identified as “Item 2100115726” will be imported as whole hides that are approximately 45 to 55 square feet each. The hides are sourced from Brazil and processed from raw hide to wet-blue state (classifiable in heading 4104 when imported in the wet state) and shipped and exported to Italy to undergo further processing as listed below. The finished article will be used as upholstery leather in the manufacture of furniture (classifiable in heading 4107). 1) Processes done in Brazil, from raw hide to wetblue state: a) Curing Fresh hides are salted or refrigerated to prevent rotting of the hides b) Soaking Raw hides are placed in water to rehydrate the leather and rinse off any salt or dirt from the hides. c) Liming/Dehairing— Hides are put in drums with lime (calcium oxide) and sodium sulfide. This raises the PH level which swells the collagen and dissolves the hair roots so the hair can be removed through the force of the drum turning. d) Fleshing—The hides go through a machine that removes leftover fat, meat and tissue from the flesh side of the hide. e) Deliming/Bating— Hides are rinsed to lower the PH and remove any lime residue. Enzymes are added to the process in soften the hide. f) Pickling— The hides are put in a drum with salt and acid to prepare the hide so it can be tanned. g) Chrome Tanning— The hides are put in a drum with Chromium sulfate salts. The Chromium links with the fibers and stabilizes the leather so it will not rot. The reaction of the hide to the Chromium salts turns the leather a light blue which is now considered a wet blue. h) Measuring— Hides are either measured by square feet or weighed. i) Packaging— The hides are folded and loaded onto skids which are wrapped in plastic before being loaded on a container for shipping to Italy 2) Processes done in Italy, from wetblue state to finished upholstery leather: a) Splitting— The leather arrives in full substance(thickness) so the tannery runs the hides through a machine and cuts it into two separate pieces. The piece with the grain is the top grain which we use. The bottom piece is a split which can be produced into leather for other intended purposes. b) Shaving— The leather is run through a machine which creates a uniform thickness on the flesh side of the hide. c) Neutralization — The hides are washed in drums with chemicals to raise the PH level from the acidic wet blue State. d) Retanning— Soaking the hides in drums with tanning agents. Helps determine the softness, grain structure and body of the leather. e) Dyeing- The hides are put in rotating drums with water based dyes for hide color penetration. f) Fatliquoring— Oils and waxes are added to the drum to ensure that the hide fibers are soft and pliable after drying. g) Setting Out— Process to remove excess water from the hides. h) Conditioning- The tannery adds a controlled uniform amount of moisture back into the hide. j) Staking - The hides are run through a mechanical machine that flexes the leather to stretch and soften the hide k) Milling— The hides are put in a large drum that rotates to further soften the leather. l) Finishing— The hides are run through spray lines where a pigment coating is applied to the surface ot the leather. A top coat is applied on top to add protection to the pigments m) Embossing— The hides are run through a machine that has a plate or roller with an engraved grain print which is applied to the leather through heat and pressure. o) Ironing— May occur if the hides need the grain to be reduced or if the hides need more or less sheen. p) Inspection -The hides are quality controlled for softness, touch, selection and all aspects for the article. q) Measuring— The hides are run through a machine that reads the square footage of the hide and both stamps the footage on the flesh side and also prints a bar code label that is adhered to the flesh side of the hide. r) Packaging— The hides are folded and placed in large cardboard boxes which are wrapped in plastic before loading onto the container for shipping to the United States. Section 19 C.F.R. § 134.1(b) defines "country of origin" as the country of manufacture, production or growth of any article of foreign origin entering the U.S. 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 Part 134. The operations performed in Italy do not substantially transform the wet blue hides. The processing in Italy is cosmetic in nature and akin to finishing operations. Accordingly, we find that the country of origin of the finished leather is Brazil. This ruling is being issued under the provisions of Part 177 of the Customs 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 Rosemarie Hayward at rosemariecasey.hayward@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division