The country of origin of Ro’s Argan Soap

N353232
September 22, 2025
OT:RR:NC:N3:136
CATEGORY: Origin Sushma Sharma Lush Manufacturing Ltd. 8680 Cambie St. Vancouver V6P 6M9 Canada RE: The country of origin of Ro’s Argan Soap Dear Ms. Sharma: In your letter dated September 3, 2025, you requested a country of origin ruling on Ro’s Argan Soap. In your submission, the subject product is identified as Ro’s Argan Soap. You state that argan oil soap base, in powder form, is made in the United Kingdom from organic argan oil, and other ingredients, in a process known as saponification. The raw materials used in the United Kingdom are sourced from various countries. The argan oil soap base is shipped from the United Kingdom to your manufacturing facility in Canada. In Canada, using several raw materials sourced from various countries, you prepare a solution mixture. Once fully dissolved and cooled down, argan oil soap base and fragrance are added. Once all ingredients are mixed and cooled down, the liquid mixture is poured into soap molds. The soap is left to set in a cold room overnight, before it is unmolded. Once the soap bars are removed from the molds, a topping mix is applied to the surface. The soap bars are wrapped in greaseproof paper, packed into boxes, and shipped to your distribution warehouse in Canada to fill orders. Once clients in the United States receive the finished soap bars, they are cut by weight based on customers’ requests, individually wrapped, labelled, and sold for use. 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 product, Ro’s Argan Soap, it is our view that the argan oil soap base imparts the finished product’s essential character. The production process in Canada does not result in a

substantial transformation of the argan oil soap base. Therefore, it is the opinion of this office that the country of origin of the finished soap bars is the United Kingdom. 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division