The country of origin of Personal Cleansing Washcloths (Wet Wipes)

N347061
April 14, 2025
OT:RR:NC:N3:136
CATEGORY: Origin Bryan Shields NuCare, LLC 4201 Sierra Point Drive Sacramento, CA 95834 RE: The country of origin of Personal Cleansing Washcloths (Wet Wipes) Dear Mr. Shields: In your letter dated March 24, 2025, you requested a country of origin ruling on Personal Cleansing Washcloths. You identify the subject merchandise as Personal Cleansing Washcloths (Wet Wipes), which will be used in healthcare related markets. This product will be utilized by patients to provide gentle, effective, personal and incontinence cleansing. The Wet Wipes are produced in two sizes (8” x 12” and 9” x 13”); they are non-sterile, single-use, and disposable. The washcloths are made from a nonwoven material and impregnated with a liquid cleansing preparation. You describe a scenario where the liquid cleansing preparation is made in Australia and imported into China in bulk containers. In China, nonwoven material is cut to size, impregnated with the liquid cleansing preparation, and packaged for retail sale for export to the United States. 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). Regarding the country of origin of the Wet Wipes, it is our view that the liquid cleansing preparation imparts the finished product’s essential character, and the nonwoven material merely serves as the carrier. In China, the cutting, impregnating, and packaging processes do not result in a substantial transformation of the liquid cleansing preparation. Therefore, it is the opinion of this office that the country of origin of the Personal Cleansing Washcloths (Wet Wipes) is Australia.

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,
Steven A. Mack Director National Commodity Specialist Division