OT:RR:NC:N5:232
Ryuichi Ishida
Wisemettac Asian Foods Inc.
13409 Orden Drive J
Santa Fe Springs, CA 90670
RE: The country of origin of “Cooked White Rice”
Dear Mr. Ishida:
In your letter dated January 20, 2026, you requested a country of origin ruling on “Cooked White Rice.” An
ingredients list, declaration origin of ingredients, and process flow diagram accompanied your request.
The subject merchandise is described as “Cooked White Rice” composed of 44.2 percent rice (product of
United States), 0.5 percent glucono delta-lactone (France), and 55.75 percent water (South Korea).
You have stated that all manufacturing is conducted in South Korea, in which ingredients of rice, and
glucono delta-lactone are soaked in water, dehydrated, and then cooked by way of steaming at temperatures
of 78-85 degrees Celsius for 14-16 minutes. The product is then cooled and packaged. The resulting product
is an individual pack of cooked rice, with a pull back removeable lid, within a microwaveable container.
There are 12 individual rice packs that are packaged into cardboard boxes with each pack weighing 210
grams.
A substantial transformation occurs when, as a result of manufacturing process, a new and different article
emerges, having a distinct name, character or use, which is different from that originally possessed by the
article or material before being subjected to the manufacturing process. See United States v.
Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940).
In Headquarters Ruling Letter (HQ) 967925, dated February 28, 2006, CBP determined that thermal
processing, or cooking did not result in the "Wild Rice" product with a different name, character, or use. The
essential character of the "Wild Rice" product was retained. The wild rice ingredient of U.S. origin had not
undergone a substantial transformation.
In this instance, the soaking, dehydration, and steaming of the rice in South Korea does not constitute a
substantial transformation. The country of origin of the pre-cooked long grain rice will be the United States.
This merchandise is subject to the Public Health Security and Bioterrorism Preparedness and Response Act
of 2002 (The Bioterrorism Act), which is regulated by the Food and Drug Administration (FDA). Information
on the Bioterrorism Act can be obtained by calling the FDA at 301-575-0156, or at the website
www.fda.gov/oc/bioterrorism/bioact.html.
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 Frank Troise at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division