The country of origin of novelty sunglasses

N351651
August 8, 2025
OT:RR:NC:N2:212
CATEGORY: Origin Daisy Zhao K.T QTOP Manufacture (Cambodia) CO.. LTD Building No. 5, National Road No.3, Prey Kdei Village Tang Doung Commune, Bati District, Takeo Province. Takeo Cambodia RE: The country of origin of novelty sunglasses Dear Ms. Zhao: In your letter dated July 24, 2025, you requested a country of origin ruling on behalf of your client, Walgreens Co. The merchandise under consideration is described as a pair of Bunny Glasses. The subject glasses consist of green or blue tinted polycarbonate lenses that are in the shape of a bunny. The temples of the glasses are of the same color as the lenses. The glasses are meant to be worn over the user’s eyes as novelty sunglasses for certain celebrations. In your request, you state that Chinese polycarbonate granules are melted and the lenses and temples are created via an injection molding process in Cambodia. The temples are attached via a screw before the finished glasses are packaged for shipment to the United States. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter 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 origin of the subject glasses, it is the opinion of this office that the polycarbonate granules are substantially transformed by the injection molding process performed in Cambodia. This process is significantly complex and creates a completely new and different article of commerce. Accordingly, the country of origin of the Bunny Glasses will be Cambodia.

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 Luke LePage at [email protected].
Sincerely,
(for) James Forkan Acting Director National Commodity Specialist Division