Country of Origin; Finished Leather

H358368
May 15, 2026
OT:RR:CTF:VS H358368 EE
CATEGORY: Origin Sarah Raymond Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP 599 Lexington Ave New York, NY 10022 RE: Country of Origin; Finished Leather Dear Ms. Raymond: This is in response to your ruling request, dated September 25, 2025, and supplemental information provided on January 14, 2026, on behalf of your client, Leather Trends Inc. d/b/a Optima Leathers (“Optima”), concerning the country of origin of certain U.S. origin wet blue hides further processed in Italy. Your request, submitted as an electronic ruling request, was forwarded to this office from the National Commodity Specialist Division for review. FACTS: The product in question is U.S. origin wet blue hides which are imported into the United States after further processing in Italy. You state that U.S. origin cattle are killed and skinned in the United States. The hides are salted or chilled to prevent rotting before further processing, thereby creating the “raw hide”. Next, the raw hides are soaked in a solution of lime and sodium sulfide to loosen and dissolve the hair while simultaneously plumping the hide (i.e., de-hairing and liming). The result is a thick, hair-free hide. Then, the flesh, fat, and connective tissue are removed from the inner side of the hide (i.e. fleshing). The de-haired and fleshed hides are immersed in chromium sulfate solution, which penetrates the hides and prevents decomposition (i.e., chrome tanning). The solution also increases the raw hides’ flexibility and strength, making it water resistant, and turns the hide blue. The result is a “wet blue” hide. Next, the wet blue hides are soaked with water. Then, a sammying machine is used to squeeze out excess water while stretching and flattening the hides (i.e. sammying). After the wet blue hides are sammyed, the processer sorts the hides by grain quality (i.e.,
2 grain grade selection). You state that clear grain with minimal scarring is designated for high-end leather buyers while grain with brands, cuts, insect bites, etc., is designated for other buyers. Last, the wet blue hides are folded or stacked and packed for exportation to Italy. Upon arrival at Mima Leathers SRL (“Mima”) in Italy, the wet blue hides are split in two to create top grain leather and split leather (i.e., split). Top grain leather is the outer surface of the wet blue hides, which is strong and smooth. The inner layer, or split leather, is processed into suede or coated leather. Next, a shaving machine is used to smooth each layer to a precise thickness, resulting in uniform hides (i.e., shaved). Mima then conducts a second grain grade selection to reduce waste and ensure that each grade of leather is finished according to its unique specifications (i.e., grain grade selection). Next, Mima re-tans each layer to soften the hide and restore flexibility. The layers are then dyed to the buyers’ specifications (i.e., coloring and re-tanning). After dyeing, the hides are dried using toggle or vacuum methods (i.e., drying of hides). Toggle drying is the process of stretching the hides on wooden frames to achieve an air-dried, firm, flat finish. Vacuum drying occurs when the hides are dried in a vacuum chamber, which is faster and preserves the hides’ softness. After drying the hides, Mima finishes the grain to achieve the finished leather’s final appearance, texture, and protective coating. Mima’s finishing processes are as follows: buffing or sanding to create smooth or suede textures; embossing to add patterns or correct grain imperfections; coating or top finishing to add protective films, pigments, or glosses; and polishing to add a shine or matte-finish to the grain. The finished leather is then sold to Optima and exported to the United States. You state that Optima sells the finished leather to various industries including residential, hospitality, aviation, and motor coach. You provided photos illustrating the leather before and after the processing in Italy and commercial documents related to the wet blue hides shipped to Italy, and the finished leather imported into the United States. ISSUE: What is the country of origin of the final leather product imported into the United States after further processing in Italy? LAW AND ANALYSIS: When determining the country of origin for purposes of applying current trade remedies, the substantial transformation analysis is applicable. 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, 69 CCPA 151 (1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 CIT 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
3 In Headquarters Ruling Letter (“HQ”) W559969, dated February 3, 1997, U.S. Customs and Border Protection (“CBP”) revoked an earlier ruling, HQ 557714, dated September 9, 1994, where CBP held that the processes performed in Mexico on wet blue split sides which consisted of shaving, re-tanning, coloring, fatliquoring, and conditioning known as “staking” resulted in a substantial transformation. In HQ W559969, CBP found that the processes performed in Mexico did not result in a substantial transformation, as the exported article, wet blue, was actually leather, and the additional operations performed to make conditioned crust leather were only finishing operations similar to those involved in HQ 556242, dated October 2, 1991. See also HQ 560381, dated June 13, 1997 (CBP found that virtually identical operations occurred in this case as in HQ W559969, except that the hides were also split in Mexico). In HQ 556242, CBP considered, the duty applicability for purposes of Note 2(b), subchapter II, Chapter 98, HTSUS, to non-perishable crust leather imported into the United States from several South American countries. The operations performed in the United States included among the following operations: 1. Re-tanning the crust for more consistent texture; 2. Coloring the crust based on the desired finished color; 3. Fatliquoring or oiling to change the texture of the leather; 4. Drying; 5. Dampening if vacuum drying was used; 6. Dry milling by tumble drying for a softer feel; 7. Toggling to stretch the hides back to yield size after shrinkage; 8. Mechanical softening to further soften the leather; 9. Embossing the leather with the desired print pattern; 10. Painting to desired color; and 11. Sealing and trimming. CBP held that the material imported into the United States did not undergo a substantial transformation by the operations performed in the United States as the operations were cosmetic in nature and the crust leather and the finished leather were the same product at different stages of production. Consistent with our previous rulings, we find that the operations performed in Italy do not substantially transform the wet blue hides from the United States. The processing in Italy is cosmetic in nature and akin to finishing operations. Accordingly, we find that the country of origin of the finished leather processed in Italy will be the United States for purposes of additional trade remedy measures. HOLDING: The country of origin of the finished leather will be the United States. Please note that 19 C.F.R. § 177.9(b)(1) provides that “[e]ach ruling letter is issued on the assumption that all of the information furnished in connection with the ruling request and incorporated in the ruling letter, either directly, by reference, or by implication, is accurate and complete in every material respect. The application of a ruling letter by a [CBP] field office to the transaction to which it is purported to relate is subject to the verification of the facts
4 incorporated in the ruling letter, a comparison of the transaction described therein to the actual transaction, and the satisfaction of any conditions on which the ruling was based.” A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is entered. If the documents have been filed without a copy, this ruling should be brought to the attention of the CBP officer handling the transaction.
Sincerely,
Monika R. Brenner, Chief Valuation and Special Programs Branch