The Country of Origin of Watermelon Seeds

N353139
September 30, 2025
OT:RR;NC:N5:232
CATEGORY: Origin Ms. Sara Morrison Onset Worldwide LLC 843 State Route 12 Frenchtown, NJ 08825 Re: The Country of Origin of Watermelon Seeds Dear Ms. Morrison: In your letter dated September 1, 2025, you requested a country of origin ruling on watermelon seeds. You state that watermelons will be grown and harvested in Sudan, with their seeds removed, dried, and cleaned there. The seeds will be shipped to India for dehulling, sifting, and packaging in 25-kilogram bags for shipment 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. Regarding the above-described watermelon seeds, this office finds that the article is not substantially transformed due to processing that is performed in India. The operations that are performed in India do not create an article with a new name, character, or use different from that possessed by the article prior to processing. Accordingly, based on the information presented, the finished good is a product of Sudan. 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 merchandise is subject to The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which is regulated by the Food and Drug Administration (FDA). Information on the Bioterrorism Act can be obtained by calling the FDA at 301-575-0156, or at the Web site www.fda.gov/oc/bioterrorism/bioact.html. This ruling is being issued under the provisions of Part 177 of Title 19 of the Code of Federal Regulations (19 C.F.R. Part177). 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 Frank Troise at [email protected].
Sincerely,
(for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division