RE: The country of origin of aluminum laminated foil

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N363694 August 19, 2026 OT:RR:NC:N5:116 CATEGORY: Origin Jun Ki Hong Guangdong BTREE New Energy Material Co., Ltd. No. 99 Airport Road Dushi Village, Pingtan Town Huiyang District, Huizhou Guangdong, South Korea RE: The country of origin of aluminum laminated foil Dear Mr. Hong: In your letter dated July 26, 2026, you requested a country of origin ruling. The product under consideration is described as aluminum laminated film intended for use with lithium-ion battery cells. You indicate that the aluminum laminated film prevents electrolyte leakage and is engineered to withstand high-pressure manufacturing while maintaining extreme formability and dimensional accuracy. The product consists of an outer layer of nylon/polyethylene terephthalate (PET) measuring 37 microns (0.037 mm) in thickness, a core layer of aluminum foil measuring 60 microns (0.06 mm) in thickness, and an inner layer of cast polypropylene (CPP) film measuring 80 microns (0.08 mm) in thickness. According to your submission, nylon/PET film of Chinese origin and an adhesive of Korean origin are sent to Thailand and made into the final product. In Thailand, the nylon/PET film are dry laminated together and then laminated to the aluminum foil that originates in Thailand by means of the adhesive. Next, the CPP film, which also originates in Thailand, is dry laminated to the foil. Finally, a slip agent coating is applied to improve the surface properties and handling of the film. The nylon/PET layer structurally supports the product and prevents tearing during deep drawing, the aluminum foil provides the primary moisture and gas barrier to ensure a hermetic seal, and the CPP layer provides electrolyte resistance and creates the final heat seal. 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).
Based upon the facts submitted, it is our determination that laminating a plastic film to a layer of aluminum foil does not result in a substantial transformation. We find that the aluminum foil, which originates in Thailand, imparts the character of the entire aluminum laminated foil. The foil is the core layer that acts as a barrier against gas, moisture, light, etc. As such, we find that the country of origin of the aluminum laminated film will be Thailand. 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. If 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, contact National Import Specialist Neil M. Cohen at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division