The country of origin of a seagrass tray and a water hyacinth cutlery caddy

N354847
October 23, 2025
MAR-2-48:OT:RR:NC:N5:130
CATEGORY: Country of Origin Ms. Sarah Ke Shine Arts(Xiamen)Inc. Unit 301, No.5 Bldg., Zhongcang Industry Area, No.29 Pingcheng West Road Haicang Dist., Xiamen, China 361026 China RE: The country of origin of a seagrass tray and a water hyacinth cutlery caddy Dear Ms. Ke: In your letter, dated September 11, 2025, you requested a binding country of origin ruling on two baskets for the purpose of duty calculation. You filed the request on behalf of your client, Walgreens Boots Alliance. The request was returned to you for additional information. The information was received by this office on October 10, 2025. Product information and photos were provided for our review. The products under consideration are a seagrass tray and a water hyacinth cutlery caddy. Both are basket-type containers made from plaiting materials. In your letter, you set forth a scenario wherein all manufacturing, from harvest of the sea grass or water hyacinth through manufacturing to packaging all occurs in Vietnam. When determining the country of origin for purposes of applying duty rates, 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). All of the manufacturing operations occur in Vietnam. The materials are transformed into baskets in Vietnam. Therefore the country of origin of the tray and caddy is Vietnam. 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 Laurel Duvall at [email protected].
Sincerely,
(for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division