N344773
OT:RR:NC:N3:348
George Tuttle, III
Tuttle Law Offices
3950 Civic Center Drive, Suite 310 San Rafael, CA 94903
RE: The country of origin of furskin rugs
Dear Mr. Tuttle:
In your letter dated December 19, 2024, on behalf of your client, Fibre by Auskin USA Inc. (“Auskin”), you requested a country of origin ruling for furskin rugs. Illustrative photographs and the assembly processes were provided for review. No samples were provided.
Style DRUS253 is a sheepskin area rug imported into the United States. It consists of multiple sheepskins sewn together in China to create a finished furskin rug.
The raw skins of sheep (classifiable in heading 4102) are preserved and undergo further processing (pre-tanning and tanning process) as listed below in New Zealand or Turkey. The tanned furskins are then exported to China to undergo further operations (as listed below). In China, the sheepskins are sewn together to create a rug (classifiable in heading 4303).
In your ruling request, you provided a summary of the operations performed in New Zealand or Turkey as well as the processes performed in China. The following is a brief summary of the information provided:
In New Zealand or Turkey
The raw sheepskins are sourced and preserved.
The pre-tanning process and tanning process occurs in New Zealand or Turkey.
The tanned sheepskins are then dried, sorted, bleached/dyed, dried again, finished, baled and exported to China.
In China
The sheepskins will be matched by color and wool length and trimmed.
The rug will be created by sewing numerous finished furskin panels together with a backing fabric.
The rug will exported to the U.S.
The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. 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 U.S. the English name of the country of origin of the article.
Section 134.1(b), Customs Regulations (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 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.”
The tanning of the raw sheepskin in New Zealand or Turkey constitutes a substantial transformation of the raw sheepskin into a new and different article, the finished tanned sheepskin, having a new name, character and use. Therefore, New Zealand or Turkey is the country of origin for Style DRUS253.
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 Rosemarie Hayward at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division