OT:RR:NC:N4:415
Philippe Reale
Beauty Industry Group Opco, LLC
1250 North Flyer Way, Suite 100
Salt Lake City, UT 84116
RE: The country of origin of a hair extension from China.
Dear Mr. Reale:
In your letter dated September 24, 2025, you requested a country of origin ruling on a hair extension.
The product under consideration is a tape-in hair extension. It is made of human hair sourced and prepared in
China and then shipped to Indonesia for construction into the final article.
The complete manufacturing process is as follows with the first three steps occurring in China and the
remaining steps being completed in Indonesia.
1. Raw Hair Processing: Raw human hair is sorted, washed, disinfected, blended, aligned, and inspected
for quality control purposes.
2. Bleach & Dye Processing: The cleansed hair is pre-treated prior to bleaching, dying with various hair
colors, drying, separation, and bonding.
3. Hair Preparation: The colored hair is divided into bundles based on the gram weight required for
each final product. For complex colors (e.g., mixed colors, highlights, lowlights), hair strands are
arranged in a specific color pattern on a preparation board.
4. Glue Sealing & Silk Mesh Gluing: Glue is applied to the top of the arranged loose hairs and then put
in an oven for the glue to dry. The glued bundle is laid flat and placed in a drying oven for full glue
drying. The glue application is repeated several times to ensure the hair is completely fixed. Silk mesh
is then also applied to the end of the bundle with the same glue formula and dried in the oven
repeatedly in the same manner.
5. Install and Cut Tape: Double-sided tape is applied to the end of the glued hair with the silk mesh.
The taped end is then cut down to a narrower width.
6.
6. Post-Treatment Conditioning: The tape-in extension is submerged and coated in a conditioning
solution to protect the hair during storage and shipment and soften the hair feel while reducing
potential tangling.
While still wet, the hair is laid flat on a preparation board and gently combed with a rat-tail comb. A
cotton cloth is placed on top to prevent heat damage during drying. The preparation board with wet
post-treatment hair is moved to a temperature-controlled drying room until the hair is fully dried.
7. Final Quality Preparation: Once dry, the hair is moved to a table to be brushed and combed
thoroughly using a wooden brush with metal teeth and a fine-tooth comb. The tape-in end is inspected,
and any loose hairs are manually removed or trimmed with stork shears. The ends of the hair are
trimmed to ensure the hair length is precisely within the scope of the product specifications.
8. Ironing and Heat Finishing: Hair is laid flat on a cotton surface. A heated flat iron (temperature
based on hair color) is applied to remove frizz and any leftover synthetic debris or glue.
9. Packaging: The finished tape-in extensions are assembled, labeled, and placed into their primary
packaging for distribution.
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 hold the opinion that this hair extension should be treated in the same manner as the products ruled upon
in New York N349850, dated June 30, 2025. As the processes performed in Indonesia would be considered
simple assembly, it would not constitute a substantial transformation due to it not being sufficiently complex
and meaningful to result in the Chinese origin hair losing its individual identity. Further, we maintain the
position that the prepared hair holds the basic nature of the finished extension and that it is not substantially
transformed to become a new article having a new name, character, or use after being further processed in
Indonesia. Accordingly, the country of origin for this tape-in hair extension will be China.
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 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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division