OT:RR:NC:N4:415
Michael E. Roll
Roll & Harris, LLP
2121 Avenue of the Stars
Los Angeles, CA 90067
RE: The country of origin of four human hair products from India.
Dear Mr. Roll:
In your letter dated June 5, 2025, you requested a country of origin ruling on four human hair products on
behalf of your client, The Hair Shop, Inc.
The products under consideration are hair wefts, wigs, tape-in hair extensions, and clip-in hair extensions.
Each of the products are made of human hair harvested and cleaned in India and then shipped to China for
construction into the final product.
The complete manufacturing process is as follows:
1. The raw human hair is collected in India.
2. The hair is cleaned and prepared for coloring.
3. The hair is then shipped to China and dyed to the desired color.
4. The hair is separated into individual hair strands by length, then reorganized and bundled according to
a specific ratio of lengths.
5. Hair extension attachments are affixed to the hair depending on the type of finished product, e.g., a
polyurethane base is applied followed by double-sided tape for tape-in extensions. For I-Tip
extensions, an adhesive base is shaped into small cylindrical tips.
6. Lastly, the finished product is packaged and prepared for shipment.
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).
In order to determine whether a substantial transformation occurs when components are assembled into
completed products, all factors such as the components used to create the product and manufacturing
processes that these components undergo are considered in order to determine whether a product with a new
name, character, and use has been produced. No one factor is decisive, and assembly/manufacturing
operations that are minimal will generally not result in a substantial transformation.
We find that the prepared hair holds the basic nature of the finished articles and that it is not substantially
transformed to become a new article having a new name, character, or use after being further processed in
China. Accordingly, the country of origin for these wefts, wigs, and hair extensions will be India.
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 CBP Regulations (19 CFR 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 Kristopher Burton at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division