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: The country of origin of chamois wash mitt and chamois demist pad
Dear Mr. Bunthanith:
In your letter dated December 17, 2025, you requested a country of origin ruling on a chamois wash mitt and
chamois demist pad, which will be imported into the United States. Samples were submitted with your
request and will be retained.
Article #74127/2, described as the NIGRIN™ “Chamois Mitt,” is leather wash mitt designed to be used for
streak-free drying and polishing of vehicles and household surfaces. The chamois wash mitt features an outer
shell made of 100 percent lamb/sheep skin, with an interior liner constructed from polyester knit fabric
laminated to a thin layer of polyurethane foam. The wash mitt measures approximately 9.5 x 6.5 inches. The
rectangular mitt is sewn along two sides. There is an opening at the bottom of the mitt for the insertion of a
hand featuring an elastic cuff made from 90 percent cotton and 10 percent spandex knit fabric to secure and
prevent the mitt from slipping off the hand. The item is packaged with a header card and imported for retail
sale.
Article #7444, described as the NIGRIN™ “Chamois Demist Pad (Chamois Sponge),” is a dual-purpose
cleaning and demisting tool used for streak-free drying and primarily for car windows and mirrors. The
chamois demist pad is constructed with a plastic foam core and covered entirely in 100 percent
lamb/sheepskin which provides a dual-action cleaning and drying surfaces. The edges of the sponge are
sewn. The rectangular shaped chamois sponge measures approximately 7 x 4 x 1 ½ inches. The item is
packaged with a header card and imported for retail sale.
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 in pieces to Cambodia
China
Elastic cotton knit fabric for the cuffs is weaved.
Foam is produced for (Article #74127/2) Chamois Mitt.
Elastic fabric and foam are exported in rolls to Cambodia.
Cambodia
For (Article #74127/2) Chamois Mitt:
The inner liner, composed of polyester knit fabric, is formed
The inner liner is laminated to the foam.
Laminated liner is cut into a shape and size.
Packaging material including header card and carton boxes and sewing thread are produced.
Components are assembled sewn into finished article.
The item is packaged with header card for retail sale and further packaged into boxes.
Merchandise is exported to the United States.
For (Article #7444) Chamois Demist Pad:
Foam is produced.
Lamb/sheepskin pieces are tanned, washed, buffed, dusted, and cut into a specific shape and size.
Components are assembled and sewn into finished article. The item is packaged with header card for retail
sale and further packaged into boxes.
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.
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 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 #74127/2 and Article #7444.
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 Vikki Lazaro at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division