RE: The country of origin of “Cooked Sticky Rice”

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 N363840 August 28, 2026 OT:RR:NC:N5:232 CATEGORY: Origin Andrew Kleckner SFC Global Supply Chain 9380 Excelsior Blvd, Suite 700 Hopkins, MN 55343 RE: The country of origin of “Cooked Sticky Rice” Dear Mr. Kleckner: In your letter dated July 29, 2026, you requested a country of origin ruling on “Cooked Sticky White Rice.” Pictorial representations of the retail packaging accompanied your request. The subject merchandise described as “Cooked Sticky White Rice” is composed of 30 to 50 percent rice (United States), 50 to 70 percent water (South Korea), and less than 1 percent glucono delta-lactone (France). The rice is grown, harvested, and dehusked in the United States before being exported to South Korea for further processing. You state that the manufacturing process is conducted in South Korea. The white rice is combined with glucono delta-lactone, soaked in water, dehydrated, and subsequently cooked by steaming at temperatures ranging from 70 to 100 degrees Celsius for 10-15 minutes. The cooked rice is then cooled, dried, and packaged in sealed, microwaveable bowls, each containing 210 grams of product. The finished product will be sold at retail in packages containing one, three, or twelve bowls. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). In Headquarters Ruling Letter (HQ) 967925, dated February 28, 2006, CBP determined that thermal processing, or cooking did not result in the "Wild Rice" product with a different name, character, or use. The essential character of the "Wild Rice" product was retained. The wild rice ingredient of U.S. origin had not undergone a substantial transformation. In this instance, the soaking, dehydration, and steaming of the rice in South Korea does not constitute a substantial transformation. The country of origin of the pre-cooked long grain rice will be the United States.
Whether an article may be marked with the phrase "Made in the USA" or similar 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. 20508 on the propriety of proposed markings indicating that an article is made in the USA. This merchandise is subject to the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which is regulated by the Food and Drug Administration (FDA). Information on the Bioterrorism Act can be obtained by calling the FDA at 301-575-0156, or at the website www.fda.gov/oc/bioterrorism/bioact.html. 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 Frank Troise at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division