Benjamin F. DeFazio
B.F. DeFazio Customs Broker
99 W. Hawthorne Avenue
Valley Stream, NY 11580

RE: Country of origin of “700-11 FG CY Blue Pigment”

Dear Mr. DeFazio:

In your ruling request dated February 24, 2021, on behalf of your client, Toyo Ink America, LLC, you requested a country of origin ruling on “700-11 FG CY Blue Pigment.”

You describe the subject product as a pigment, which is produced in Japan, incorporating various raw materials from Korea, India, China, and Japan. You describe the raw material from Korea as Phthalocyanine Crude A (Key Raw Material, 30.77% of product composition). You describe the raw material from India as Phthalocyanine Crude B (Key Raw Material, 30.77% of product composition). You describe the raw materials from China as Phthalocyanine Crude C (Key Raw Material, 31.00% of product composition), Phthalocyanine Crude D (Key Raw Material, 3.28% of product composition), and Pigment Derivatives (Key Raw Material, 2.46% of product composition). You described the raw materials from Japan as subsidiary raw materials.

The production process in Japan consists of the following steps:

Pigmentation of Phthalocyanine Crude A, Phthalocyanine Crude B, and Pigment Derivatives (Intermediate 1) Pigmentation of Phthalocyanine Crude C (Intermediate 2) Synthesis with Chemical Reaction of Phthalocyanine Crude D (Intermediate 3) Mixing Intermediates 1, 2, and 3 Milling Packaging, Inspection, and Storage In 19 C.F.R. § 134.1(b), “country of origin” is defined 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 this part.”

With respect to the subject product, we have determined that the production process in Japan using raw materials from Korea, India, China, and Japan, does not result in a substantial transformation of the key raw materials of Korean, Indian, and Chinese origin. Therefore, in our opinion, the country of origin for the subject product is Korea, India, and China.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 3204.17, HTSUS, unless specifically excluded, may be subject to an additional 25 percent ad valorem rate of duty.  At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 3204.17, HTSUS, listed above.   The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading.  For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at and, respectively.

This merchandise may be subject to the requirements of the Toxic Substances Control Act (TSCA), which are administered by the U.S. Environmental Protection Agency (EPA).  Information on the TSCA can be obtained by contacting the EPA at Document Control Office (7407M), Office of Pollution Prevention and Toxics (OPPT), Environmental Protection Agency, 1200 Pennsylvania Avenue, N.W., Washington, D.C., 20460, by calling the Toxic Substances Control Act Hotline at (202) 554-1404, by e-mailing to [email protected], or by visiting their website at

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, contact National Import Specialist Nuccio Fera at [email protected].


Steven A. Mack
National Commodity Specialist Division