OT:RR:NC:N3:136
Aaron Applebaum
Sidley Austin LLP
1501 K Street, N.W.
Washington, DC 20005
RE: The country of origin of Wet Wipes
Dear Mr. Applebaum:
In your letter dated August 9, 2025, on behalf of your client, Kimberly-Clark Global Sales, LLC, you
requested a country of origin ruling on Wet Wipes.
You identify the subject product as Cottonelle® flushable wet wipes. The Wet Wipes are pre-moistened
disposable wipes designed for personal hygiene. They are made of nonwoven cloth-like material (basesheet),
that is flushable in that it weakens and disperses when agitated in water. The basesheet is impregnated with a
proprietary aqueous solution that enables the Wet Wipes to clean the intended area of the body. The Wet
Wipes are designed for all toileting occasions and populations. You state that consumers purchase the Wet
Wipes for a thorough cleanse, deodorizing refresh, and management of odor-causing bacteria.
The proprietary cleansing solution is manufactured in South Korea using ingredients sourced from various
countries. You state these ingredients impart the solution with features that are critical to the functioning of
the finished Wet Wipes, such as moisturizing and cleansing the user’s skin, and inhibiting the growth of
bacteria, mold, and yeast.
The solution is applied to the basesheet during final production in South Korea. Rolls of nonwoven basesheet
, which function as the carrier for the proprietary solution, are manufactured in China. The Chinese basesheet
is shipped to South Korea, where it is unwound, slit, impregnated with the South Korean proprietary solution,
folded, cut, stacked, compressed and packaged for retail sale, and packed for export to the United States.
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).
Regarding the country of origin of the Wet Wipes, it is our view that the South Korean proprietary cleansing
solution imparts the finished product’s essential character, and the Chinese basesheet material serves as the
carrier. Therefore, it is the opinion of this office that the country of origin of the Wet Wipes is South Korea.
This merchandise may be subject to the Federal Food, Drug, and Cosmetic Act and/or The Public Health
Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which are
administered by the U.S. Food and Drug Administration (FDA). Information on the Federal Food, Drug, and
Cosmetic Act, as well as The Bioterrorism Act, can be obtained by calling the FDA at 1-888-463-6332, or by
visiting their website at www.fda.gov.
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 Nuccio Fera at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division