OT:RR:NC:N4:441
Mr. Nhep Bunthanith
Tomkins Chamois (Cambodia) Co., Ltd.
Land No. 560, Oukorki Village, Tang Krouch Commune, Samrong Tong District
Phnom Penh 050111, Cambodia
RE: Country of origin determination for a chamois leather cleaning cloth
Dear Mr. Bunthanith:
In your letter dated December 17, 2025, you requested a country of origin determination for a chamois
leather cleaning cloth, imported into the United States. A sample was submitted with your request and will
be retained.
Article #74129/1, described as the NIGRIN™ “Chamois Leather ca. 2323 cm2,” is a leather cleaning cloth
made from lamb/sheepskin designed to be used for streak-free drying and polishing of vehicles and
household surfaces.
You have indicated that the locations of the manufacturing operations are as follows:
New Zealand
Lamb/sheepskin is sourced.
Lamb/sheepskin is pickled and exported to Cambodia.
Cambodia
Lamb/sheepskin pieces are tanned, washed, buffed, dusted, and cut into a specific shape and size.
Packaging material including header card and carton boxes are produced.
The item is packaged with header card for retail sale and further packaged into boxes.
The merchandise is exported to United States.
The raw skins of lamb/sheep (classifiable in heading 4107) are pickled and persevered in New Zealand and
undergo further processing in Cambodia which include tanning, washing, buffing and cut into specific shape
according to client’s specifications to create a cleaning cloth (classifiable in heading 4205).
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.”
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. U.S., 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. U.S., 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
The tanning of the raw lamb/sheepskins in Cambodia constitutes a substantial transformation of the raw
lamb/sheepskin into a new and different article, the finished tanned sheepskin, having a new name, character
and use. Therefore, Cambodia is the country of origin for Article #74129/1.
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 [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division