The country of origin of Lens Cleaning Wipes

N360826May 14, 2026OT:RR:NC:N3:136
CATEGORY: OriginWilliam MaloneySandler, Travis & Rosenberg, P.A.286 Madison Avenue - Suite 1200New York, NY 10017RE: The country of origin of Lens Cleaning WipesDear Mr. Maloney:In your letter dated
April 17, 2026
, on behalf of your client, 7051395 Canada Inc. dba HTA Direct Sourcing,you requested a country of origin ruling on Lens Cleaning Wipes.In your submission, the subject products pre-moistened lens cleaning wipes identified asare described as “Lens Cleaning Wipes,” Item # 1064689 (foil wrapped) and Item #1064690 (pop-up container).The disposable cleaning wipes are composed of a base sheet of tissue paper made from wood pulp cellulose thatserves as the carrier for a mixture of detergent, solvent/cleaner, water and isopropyl alcohol.The, pre-moistened wipes are used by consumers to clean prescription eyeglass lenses, sports goggles, sunglasses,scopes, CD’s, DVD’s, etc.The wipes will be imported in packaging configurations: the following (1) Individual wipe foil wrapped: The rectangular foil wrapped wipes will be imported in two sizesthat measure approximately 6"x5" or 7"x5".The small individual sheets are saturated with the sterile cleaning solutionfolded, packaged into individual foil packets, and boxed for sale., (2) Pop-up container: pop-up container with a roll of 100 perforated, each sheet tears apartA wipesfrom the roll of 100 as the consumer pulls a sheet from the container.The rectangular wipes on the perforated roll will measure approximately 5.11" x 7.8"are saturated with the sterile cleaning and solution.The paper that serves as the carrier for the cleaning solution is described as cellulose-based nonwoven paper,medical/optical grade, that has a wet strength of 40 GSM.The paper will be manufactured in China from wood pulpsing either a mechanical or air processThe pulp is dispersed in water and mechanically refined u. to achieve the right fiber length and bonding ability.The lens cleaning solution will consist of nited States originSodium dodecyl sulfate (detergent) andU Dipropylene glycol monomethyl ether (non-detergent solvent/cleaner)be diluted in China with, which will water and isopropyl alcohol.
Processing in ChinaU.S. origin detergent and non-detergent solvent/cleaner will be diluted with water and isopropyl alcohol to China, the wood pulp jumbo rolls are unrolled and cut (length and width)prepare the cleaning solution. Ininto individual rectangular pieces of 5"x 7" or 5" x 6”.These small individual sheets are saturated with cleaning solutionfolded, packaged into individual foil packets, and boxed into cases containing either 1,000, or 3,000 individual foil wrapped wipes.For the pop-up container wipes, the jumbo rolls are cut into lengths and perforated so that each cut piece has 100 pull apart towelettes.These 100 towelette units are saturated with the cleaning solutionrolled and placed into the pop-up container., ,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 asubstantial 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 Lens Cleaning Wipes, it is our view that the cleaning solution impartsthe wipe’s essential characterThe processing in China,, while the nonwoven sheets serve as the carrier. which includes .S. origin detergent and non-detergent solvent/cleane diluting the Urwith water and isopropylcutting and perforating the nonwovens to size, impregnating the cleaning solution into the Chinesealcohol, nonwovens, and packaging processes, do not result in a substantial transformation of the orU.S. components fcountry of origin purposes under 19 U.S.C. 1304Therefore, it isthe opinion of this office that the country of. origin of the Lens Cleaning Wipes ill be wthe United States.You also requested confirmation that as products of the United States, the subject products will not be subjectthe additional duties imposed on certain products of China under to Section 301or Section 122 measures. Since the finished Lens Cleaning Wipes will be imported as products of the United States, neither Section301 nor Section 122 measures will apply.If a good is determined to be an article of U.S. origin, it is not subject to the country of origin markingrequirements of 19 U.S.C. §1304. Whether an article may be marked with the phrase “Made in the USA” orsimilar words denoting U.S. origin, is an issue under the authority of the Federal Trade Commission (FTC). We suggest that you contact the FTC Division of Enforcement, 600 Pennsylvania Avenue, N.W.,Washington, D.C. 20580, or through the FTC’s website at http://www.ftc.gov, on the propriety of proposedmarkings indicating that an article is made in the U.S.This merchandise may be subject to the Federal Food, Drug, and Cosmetic Act and/or The Public HealthSecurity and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which areadministered by the U.S. Food and Drug Administration (FDA). Information on the Federal Food, Drug, andCosmetic Act, as well as The Bioterrorism Act, can be obtained by calling the FDA at 1-888-463-6332, or byvisiting their website at www.fda.gov.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Nuccio Fera at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division