CLA-2-39:OT:RR:NC:N4:422
Mr. Benedict Chan
Ecorigin Investment Pte. Ltd.
12 Woodlands Square, #08-69, Tower 1, Singapore 737715
Singapore 737715
RE: The tariff classification and country of origin of a plastic scrub sponge
Dear Mr. Chan:
In your letter dated December 29, 2025, you requested a tariff classification and country of origin
determination ruling on a plastic scrub sponge. Photographs, a BOM (Bill of Materials), and the sponge
production process were submitted for our review.
The merchandise is a plastic scrub sponge, part number SP-001. The round sponge is primarily made of a
polyether plastic material combined with a Toluene Diisocyanate (TDI) based polymer plastic. The scrub
sponge features a hole in its center and blue on top and yellow on the bottom. The scrub sponge is intended
for household cleaning.
Manufacturing Steps:
Raw materials consist of approximately 80% polyether originating in Germany and 20% TDI-based polymer
originating in China. Raw materials are mixed in proportion and then polymerized and foamed. This is
performed in China.
High-temperature stirring and foaming. This is performed in China.
Cut into small pieces of sponge, rough cutting for storage and transportation. This is performed in China.
Cut horizontally into a slice. This is performed in Malaysia or Thailand.
Die-cutting. This is performed in Malaysia or Thailand.
Packing and packed into a warehouse. This is performed in Malaysia or Thailand.
You proposed classification of the plastic scrub sponge in subheading 3924.90.0000. We disagree. That
subheading is incorrect and does not exist.
The applicable subheading for the plastic scrub sponge, part number SP-001 will be 3924.90.5650,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Tableware, kitchenware,
other household articles and hygienic or toilet articles, of plastics: Other: Other. Other.” The general rate of
duty will be 3.4 percent ad valorem.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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).
This office reviewed the provided product process information and is of the opinion that the processing
conducted in China, results in a substantial transformation. These components lose their individual identities
and become an integral part of a new article, possessing a new name, character, and use. Accordingly, from
the details submitted, the country of origin for the plastic scrub sponge would 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 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 Dana L. Giammanco at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division