The country of origin of polypropylene glycol (PPG)

N358313
February 11, 2026
OT:RR:NC:N5:137
CATEGORY: Origin Sunmi Jung Mutual Standard Co., Ltd 11 Magokjungang-ro, Gangseo-gu Seoul 07797 South Korea RE: The country of origin of polypropylene glycol (PPG) Dear Ms. Jung: In your letter dated January 29, 2026, you requested a country of origin ruling on polypropylene glycol (PPG) on behalf of your client, PUcore Co., Ltd. The product under consideration is referred to as Base Yukol. It is a polyol (polypropylene glycol, PPG). It is used primarily in polyurethane foam and elastomer applications, as well as in resin intermediates and industrial chemical formulations. When determining the country of origin for purposes of applying current trade remedies and 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). Base Yukol is manufactured entirely in Korea via the polymerization of Korean origin propylene oxide and ethylene oxide along with other Korean origin inputs. As all the components are Korean origin and the polymerization process takes place in Korea, the country of origin of the polypropylene glycol, for duty and marking purposes is Korea. In Korea, Chinese origin triethyl phosphate is blended with the Korean origin polypropylene glycol to give it additional flame-retardant properties. The addition of the triethyl phosphate does not result in further polymerization or chemical reactions, therefore, no substantial transformation occurs. The country-of-origin of the PPG blended with triethyl phosphate, for duty and marking purposes will remain Korea.

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 Christina Allen at [email protected].
Sincerely,
(for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division