The country of origin of Disinfecting Wipes

N358105
February 9, 2026
OT:RR:NC:N3:136
CATEGORY: Origin Matthew Bock Bock Trade Law 53 State Street, Suite 500 Boston, MA 02109 RE: The country of origin of Disinfecting Wipes Dear Mr. Bock: In your letter dated January 22, 2026, on behalf of your client, Biom Innovations Inc., you requested a country of origin ruling on Disinfecting Wipes. In your submission, the subject products are identified as P-60WIP-DSN-CIT, Disinfecting wipe roll, 60ct, Fresh Citrus and P-60WIP-DSN-ALP, Disinfecting wipe roll, 60ct, Alpine Mint. These wipes are intended as household disinfecting products for hard, non-porous surfaces, and consist of: 1. U.S.-origin, EPA-registered formulation disinfecting concentrate. 2. U.S.-origin fragrance. 3. A Chinese-origin nonwoven substrate 4. A pouch that serves as packaging. You describe a scenario where disinfecting concentrate, which includes biodegradable detergents of U.S. origin and fragrance of U.S. origin will be shipped to a production facility in China. In China, the concentrate will be diluted with deionized water and mixed with the fragrance solution. This solution will be used to soak Chinese-origin nonwoven substrate sheets (wipes), which are cut to the required width and perforated (3.35” x 8.25”). The impregnated sheets will be inspected and packaged into retail pouches for export to the United States. When determining the country of origin for purposes of applying current trade remedies under Section 301and 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 country of origin of the Disinfecting Wipes, it is our view that the U.S. origin disinfecting concentrated solution imparts the finished Disinfecting Wipes’ essential character. We do not believe that the diluting of the disinfecting concentrate, cutting and perforation of the nonwoven sheets, impregnation of the diluted disinfecting solution and fragrance, and packing processes in China result in a substantial transformation of the concentrated disinfecting solution of U.S. origin, Therefore, it is the opinion of this office that the country of origin for the finished Disinfecting Wipes is the United States. 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