The country of origin of hydrogenated rosin ester

N358172
February 17, 2026
OT:RR:NC:N3:135
CATEGORY: Origin Joji Araki Arakawa Chemical USA Inc. 625 N. Michigan Ave Chicago, IL 60611 RE: The country of origin of hydrogenated rosin ester Dear Mr. Araki: In your letter dated January 24, 2026, you requested a country of origin ruling on hydrogenated rosin ester The item under consideration is hydrogenated rosin ester. You have indicated that in Brazil, crude gum rosin undergoes washing, distillation, and purification. Subsequently, in China, this rosin is subjected to hydrogenation and esterification processes to produce the final hydrogenated rosin ester. 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). In determining whether a substantial transformation occurs in the manufacture of products from chemicals, Customs has consistently examined whether a chemical reaction occurs when two chemicals are mixed in the production of the final article. In this case, the hydrogenated rosin ester is produced in China from rosin through both hydrogenation and esterification processes. These processes alter the stability, color, and odor of the Brazilian rosin and make the hydrogenated rosin ester superior for specific, high-performance applications. Since the imported product undergoes two distinct chemical reactions and changes in chemical stability, physical properties, and use, the country of origin of the hydrogenated rosin ester will be China. 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 Fei Chen at [email protected].
Sincerely,
(for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division