CLA-2-34:OT:RR:NC:N3:136
Antonia Serrell-Watts
The World of Bliss
8 The Green, STE A
Dover, DE 19901
RE: The tariff classification, country of origin, and marking of RollaWipe from Cambodia
Dear Ms. Serrell-Watts:
In your letter dated August 27, 2026, you requested a tariff classification, country of origin, and marking
ruling on RollaWipe.
In your submission the subject product is described as a roll of pre-moistened, flushable, personal-cleansing
wipes, made from plant-derived nonwoven spunlace material, which are impregnated with a surface-active
cleaning preparation. The wipes are perforated and wound onto a polypropylene center tube in roll form and
are designed to be dispensed from a conventional toilet paper holder. The finished product contains
approximately 240 perforated wet sheets on a roll. The roll is approximately 114 mm wide and is supported
by a plastic center tube. The finished roll incorporates a protective flexible barrier film and a plastic
dispensing/closure component that allows the consumer to access individual wet sheets while helping retain
moisture. The product is intended for personal cleansing after toileting.
The applicable subheading for the RollaWipe will be 3401.11.5000, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for which provides for Soap; organic surface-active products and
preparations for use as soap, in the form of bars, cakes, molded pieces or shapes, whether or not containing
soap; organic surface-active products and preparations for washing the skin, in the form of liquid or cream
and put up for retail sale, whether or not containing soap; paper, wadding, felt and nonwovens, impregnated,
coated or covered with soap or detergent: Soap and organic surface-active products and preparations, in the
form of bars, cakes, molded pieces or shapes, and paper, wadding, felt and nonwovens, impregnated, coated
or covered with soap or detergent: For toilet use (including medicated products): Other. The general rate of
duty will be free.
You asked about special tariff treatment. Products from Cambodia imported into the United States, classified
under subheading 3401.11.5000 are free of duty. They are not eligible for any other preferential tariff
treatment, special trade program, free trade agreement, duty preference, exemption, exclusion, or other
special tariff treatment.
Country of Origin
Origin of Components:
China - Pre-converted (viscose, wood pulp) plant-derived (flushable) nonwoven spunlace roll, already
perforated and mounted on a polypropylene (PP) plastic center tube.
Role in finished product: Finished wipe substrate roll ready for wetting and final assembly.
China- Polypropylene (PP) dispensing/closure clip and polypropylene flanges.
Role in finished product: Dispensing, closure, and structural features.
China- Concentrated liquid cleaning preparation.
Role in finished product: Used to prepare the wetting/cleansing solution.
Vietnam- Flexible Polyethylene Terephthalate / Polyethylene (PET/PE) plastic barrier film.
Role in finished product: Moisture barrier and outer wrap.
Vietnam- Hot-melt pressure sensitive adhesive (HMPSA).
Role in finished product: Affixes closure clip and barrier film/side components.
Cambodia- Distilled/purified water (approximately 99.2% of the final wetting solution) and
manufacturing operations. Role in finished product: Water for final solution; wetting, assembly,
sealing, QC, and packaging.
Scenario A:
The concentrated liquid cleaning preparation will be manufactured in China and imported into
Cambodia. In Cambodia, the concentrate will be mixed with distilled/purified water sourced or
produced in Cambodia to prepare the final wetting solution, which is applied to the perforated
nonwoven wipes of Chinese origin, followed by the Cambodian manufacturing operations described
below.
Scenario B:
The individual chemical ingredients required for the RollaWipe wetting solution may originate in
China and/or other countries and would be imported separately into Cambodia as individual raw
ingredients rather than as a pre-formulated cleansing concentrate. In Cambodia, those ingredients
would be measured, blended, and formulated with Cambodian distilled/purified water according to
the RollaWipe formulation to create the finished cleansing/wetting preparation. The
Cambodian-formulated cleansing preparation would then be applied to the imported pre-converted
nonwoven rolls, followed by the Cambodian manufacturing operations described below.
Manufacturing Operations Performed in Cambodia:
1. Receipt and inspection of imported raw materials and components.
2. Preparation or sourcing of distilled/purified water.
3. Metering and mixing the Chinese-origin concentrate with approximately 99.2% distilled/purified
water under Scenario A, or measuring, blending and formulating the individual liquid ingredients in
Cambodia under Scenario B.
4. Receiving the nonwoven rolls already converted, perforated into approximately 240 separable
sheets, formed into roll configuration, and mounted on plastic center tubes.
5. Applying the prepared wetting solution to the nonwoven.
6. Applying the flexible moisture-barrier film around the wet roll.
7. Applying hot-melt adhesive at designated attachment points.
8. Attaching the RollaWipe dispensing/closure component to the finished roll.
9. Sealing the product to maintain moisture.
10. Final assembly.
11. Quality-control inspection.
12. Retail wrapping and packaging.
13. Preparation of the finished RollaWipe product for export to the United States.
Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the
country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP
Regulations (19 CFR 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 the marking laws and regulations. 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).
With respect to scenario A, we have determined that the production process described above does not result
in a substantial transformation of the Chinese origin concentrated liquid cleaning preparation, which we
believe imparts the finished product’s essential character. Therefore, in our opinion, the country of origin for
the finished RollaWipe for duty and marking purposes is China. The country of origin marking requirements
of 19 U.S.C. § 1304 and 19 C.F.R. Part 134 will be satisfied with the use of the words “Made in China,”
“Product of China,” or other words of similar meaning.
With respect to scenario B, we have determined that the production process described above results in a
substantial transformation of the individual raw ingredients used to produce the impregnating liquid cleaning
preparation, which we believe imparts the finished product’s essential character. Therefore, in our opinion,
the country of origin for the finished RollaWipe for duty and marking purposes is Cambodia. The country of
origin marking requirements of 19 U.S.C. § 1304 and 19 C.F.R. Part 134 will be satisfied with the use of the
words “Made in Cambodia,” “Product of Cambodia,” or other words of similar meaning.
Marking
Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every
article of foreign origin imported into the United States 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 United States, the English name of the country of origin of the
article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to
know by an inspection of the marking on the imported goods the country of which the goods is the product.
The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by
knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should
influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940).
As provided in section 134.41(b), Customs Regulations (19 CFR 134.41(b)), the country of origin marking is
considered conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read it
without strain. Part 134.1(d) defines the "ultimate purchaser" generally as the last person in the U.S. who will
receive the article in the form in which it was imported.
With regard to the permanency of a marking, section 134.41(a), Customs Regulations (19 CFR 134.41(a)),
provides that as a general rule, marking requirements are best met by marking worked into the article at the
time of manufacture. For example, it is suggested that the country of origin on metal articles be die sunk,
molded in, or etched. However, section 134.44, Customs Regulations (19 CFR 134.44), generally provides
that any marking that is sufficiently permanent so that it will remain on the article until it reaches the ultimate
purchaser unless deliberately removed is acceptable.
With respect to your inquiry concerning marking of the outermost surface of the retail packaging containers,
this office notes that Section 134.32 sets forth a limited list of conditions that may render an article excepted
from the marking requirements set forth in 19 C.F.R. Part 134.11. Specifically, 19 C.F.R. Part 134.32(d),
addresses the marking of articles imported in containers:
(d) Articles for which the marking of the containers will reasonably indicate the origin of the articles.
The general rules for marking articles excepted under Section 134.32 are set forth in 19 C.F.R. Part
134.22(a), which provides as follows:
Contents excepted from marking. When an article is excepted from the marking requirements by
subpart D of this part, the outermost container or holder in which the article ordinarily reaches the
ultimate purchaser shall be marked to indicate the country of origin of the article whether or not the
article is marked to indicate its country of origin.
Upon review of the facts presented, we have determined that the articles may be excepted from the marking
requirements if the outermost container in which the RollaWipes ordinarily reach the ultimate purchaser are
properly marked to indicate the country of origin.
You have also asked about the retail packaging displaying a United States business or mailing address.
Section 134.46 deals with cases in which the words “United States,” or “American,” the letters “U.S.A.,” any
variation of such words or letters, or the name of any city or locality in the United States, or the name of any
foreign country or locality other than the country or locality in which the article was manufactured or
produced, appears on an imported article or its container, and those words, letters or names may mislead or
deceive the ultimate purchaser as to the actual country of origin. In such a case, there shall appear, legibly
and permanently, in close proximity to such words, letters, or name, and in at least a comparable size, the
name of the country of origin preceded by “Made in, Product of,” or other words of similar meaning.
In order to satisfy the close proximity requirement, the country-of-origin marking must generally appear on
the same side(s) or surface(s) in which the name or locality other than the actual country of origin appears.
This merchandise may be subject to the Federal Food, Drug, and Cosmetic Act and/or The Public Health
Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which are
administered by the U.S. Food and Drug Administration (FDA). Information on the Federal Food, Drug, and
Cosmetic Act, as well as The Bioterrorism Act, can be obtained by calling the FDA at 1-888-463-6332, or by
visiting their website at www.fda.gov.
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 the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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 Nuccio Fera at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division