The country of origin of abrasive discs.

N360536
April 15, 2026
OT:RR:NC:N1:128
CATEGORY: Origin Ms. Elina Högkulla Mirka Ltd Pensalavagen 210 Jeppo 66850 Finland RE: The country of origin of abrasive discs. Dear Ms. Högkulla: In your letter dated April 8, 2026, you requested a country of origin ruling. The merchandise at issue is described as the Mirka Iridium SR PSA and Mirka Iridium SR Grip. They are abrasive discs designed to be affixed to tools in order to sand epoxy, acrylic, and other resin-based surfaces on road, aerospace, rail, and marine vehicles. From the information you provided, the manufacturing process of the Mirka Iridium SR PSA is as follows: the “Jumbo J1 roll,” which consists of artificial silicon carbide abrasive grains affixed to a PET film backing, is imported into Finland from China. A roll of “release paper” is imported into Finland from Italy. In Finland, a pressure-sensitive adhesive is applied to the back of the Jumbo J1 roll. The Jumbo J1 roll is then laminated onto the release paper. This material is laser-cut, resulting in multiple individual discs on the uncut roll of release paper. In use, the discs are peeled off the release paper and affixed to tools using the pressure-sensitive adhesive. For the Mirka Iridium SR Grip, the Jumbo J1 roll is imported into Finland from China. “Grip fabric,” which has a hook-and-loop backing, is imported into Finland from Italy. In Finland, the Jumbo J1 roll is laminated to the grip fabric. This material is then laser-cut into separate, individual discs. In use, the discs are affixed to tools using the hook-and-loop backing. 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).

With regards to the Mirka Iridium SR PSA and Mirka Iridium SR Grip, the Jumbo J1 roll is manufactured in China, and is identifiable upon importation into Finland as abrasive grain affixed to a PET film backing. The processing which occurs in Finland enhances the functionality of the abrasive grain material, but does not change its fundamental name, character or use, and does not constitute substantial transformation. Therefore, the country of origin of the Mirka Iridium SR PSA and Mirka Iridium SR Grip 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 Nicole Sullivan at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division