CLA-2-39:OT:RR:NC:N5:137
Frank Zhou
Evergrace Home Inc
Floor 5, No.2000 Pudong Avenue,
Shanghai, 200135
China
RE: The tariff classification and country of origin of regenerated cellulose sponge sheets
Dear Mr. Zhou:
In your letter dated August 21, 2025, you requested a tariff classification and country of origin determination
ruling.
Item number 1741726 is referred to as a Swedish Dishcloth. The samples provided are sponge sheets are
rectangular shapes with 90-degree corners, measuring 12 in. by 10 in. They are screen printed with various
designs but are not further worked. These reusable sponge sheets will be used for household cleaning
purposes, with the goal to reduce the use of paper towels. The sponge sheets will be imported cut to size and
packaged for retail sale.
The sponge sheets are manufactured, in Germany, from a mixture of 70 percent cellulose, in the form of
viscose, a dissolved liquid cellulose, and 30 percent scrap cotton fibers. The mixture undergoes a several step
process, including salting before being extruded into a sheet. The sheet is subjected to a process to regenerate
the viscose back into cellulose. It is then treated by indirect steam heating to remove the salt, creating the
pores in the finished sponge sheet that increase its absorptive qualities. After drying the sheets are cut into the
desired sizes.
The finished greige sheets are shipped to China where they will be printed and packaged for shipment to the
United States.
The applicable subheading for the regenerated cellulose sponge sheets will be 3921.14.0000, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for other plates, sheets, film, foil and strip, of
plastics: cellular: of regenerated cellulose. The general rate of duty will be 6.5 percent ad valorem.
When determining the country of origin for purposes of applying current trade remedies under Section 301
and additional duties, 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).
The printing and packaging processes conducted in China constitute minor processing that does not result in
a substantial transformation. Therefore, the country of origin of the regenerated cellulose sponge sheets will
be Germany.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of the European
Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15
percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General
duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.02.20, in addition to subheading 3921.14.0000, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided
for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying
duty rates are provided at https://hts.usitc.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 Christina Allen at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division