MAR-2-46:OT:RR:NC:N5:130
Ms. Jo-Anne Daniels
Jo-Anne Daniels DBA Trade Resources & Associates
230-B Tyson Avenue
Paris, TN 38242
RE: The country of origin of a jute and cotton bag
Dear Ms. Daniels:
In your letter, dated January 19, 2026, you requested a binding country of origin ruling on behalf of your
client, Crane USA Inc. The ruling was returned to you for additional information, which was received by this
office on February 9, 2026. The ruling was requested for a jute and cotton bag for purposes of trade remedy
applicability. Product information and a sample were provided for our review.
The product under consideration is item BC-110SB-2 Jute Storage Carry Bag. The cylindrical bag has a
coiled, braided (plaited), and stitched jute bottom and the sides are constructed of a woven cotton fabric and
coiled and stitched jute braids (plaits). You describe a scenario wherein the jute is grown and harvested in
Uzbekistan and the cotton is grown, harvested, and woven into fabric in Uzbekistan. The cotton fabric is
then shipped to India where it is cut to shape. In India, the jute fiber is braided, coiled and stitched to circular
shape, coiled and stitched to cylindrical shape, and sewn together with the cut cotton fabric. You indicate
that the jute is made into yarn in Uzbekistan; this is incorrect. The jute fiber in the bag is not spun into yarn;
the jute fibers are only bunched and braided. Tassels and a cotton fabric lining are also added in India. The
jute fibers constitute plaiting material and the jute predominates in surface area over the cotton. The finished
bag is an article of plaiting materials of Chapter 46.
When determining the country of origin for purposes of applying duty rates, 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).
There is considerable precedent that the substantial transformation occurs when the pieces of fabric are cut to
shape. See HQ rulings 083461 (May15, 1990), 555189 (June 12, 1989), 554027 (January 13, 1987), 554025
(December 16.1986), amongst others. In this case, the cotton fabric is cut to shape in India. But the more
significant substantial transformation takes place where the jute fiber is braided, coiled, and stitched to shape
into components of an article of plaiting material, namely, a bag. The jute is braided in India and then it is
stitched into circular and cylindrical defined bag pieces in India. The jute bag components are made to shape
and the cotton component is cut to shape in India. Therefore, the country of origin will be India.
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 Laurel Duvall at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division