The country of origin of Baby Wipes

N351552
August 12, 2025
OT:RR:NC:N3:136
CATEGORY: Origin Tom Gould Tom Gould Customs Consulting, Inc. 16475 466th Pl SE North Bend, WA 98045 RE: The country of origin of Baby Wipes Dear Mr. Gould: In your letter dated July 21, 2025, on behalf of your client, Coterie Baby, Inc, you requested a country of origin ruling on Baby Wipes. You identify the subject merchandise as nonwoven baby wipes, impregnated with a liquid soap preparation. You describe a scenario where concentrated liquid soap is produced in South Korea with ingredients sourced from South Korea, Indonesia, Holland, and China. The soap’s formulation consists of specific proportions of water, glycerin, sodium benzoate, citric acid, caprylyl glycol, and decyl glucoside. We agree that the ingredients used in producing the concentrated liquid soap are substantially transformed into a new product of South Korea. You state that the concentrated liquid soap is transported from South Korea to a finishing and packaging facility in China, where the soap concentrate is diluted with water and pH-balanced with a small amount of citric acid, which does not result in a chemical reaction. The diluted solution is then impregnated onto nonwoven fabric, cut to specific dimensions, packaged into the final product, and shipped 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 subject Baby Wipes, it is our view that the liquid soap preparation imparts the finished product’s essential character, and the nonwoven material serves as the carrier. In China, the dilution, impregnating, cutting, and packaging processes do not result in a substantial transformation of

the concentrated liquid soap preparation. Therefore, it is the opinion of this office that the country of origin of the nonwoven baby wipes is South Korea. 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 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 Forkan Acting Director National Commodity Specialist Division