RE: The country of origin and marking of a ceramic honeycomb catalyst

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 N364629 September 14, 2026 OT:RR:NC:N3:135 CATEGORY: Origin; Marking Hak Kil Kim JW Customs Advisory Service, Inc. #1804, 147, Teheran-ro, Gangnam-gu Seoul 06132 South Korea RE: The country of origin and marking of a ceramic honeycomb catalyst Dear Mr. Kim: In your letter dated August 27, 2026, on behalf of Cleansky Co., LTD, you requested a country of origin and marking ruling on a ceramic honeycomb catalyst. The product under consideration is a ceramic honeycomb catalyst consisting of a ceramic honeycomb substrate and a washcoat layer (catalyst coating layer) impregnated with precious metals. At the time of import, it is a fully finished catalyst capable of performing its catalytic functions. After importation, it will be assembled into a catalytic converter in the United States. The manufacturing process for the ceramic honeycomb catalyst is described as follows: US-origin alumina (Model: MI-386 SP), Germany-origin alumina (Model: Sba-200), China-origin oxygen storage component (OSC) (Model: Actalys-063), Japan-origin barium hydroxide, South Korea-origin acetic acid, China-origin octyl alcohol, Malaysia-origin monoethanolamine (MEA), and South Korea-origin palladium nitrate, rhodium nitrate, and distilled water are weighed to prepare a catalyst coating solution. The distilled water, acetic acid, barium hydroxide, alumina (MI-386 SP and Sba-200), and OSC are added for the primary mixing. Subsequently, palladium nitrate and rhodium nitrate are added along with MEA, which serves to maintain the precious metal precursors in a stable complex state. A final mixing is then performed to complete the catalyst coating solution. The pH, solid content, and particle size of the completed catalyst coating solution are measured, and if they meet the standard values, the coating process proceeds. Before coating, the weight of the China-origin ceramic honeycomb is measured. The ceramic honeycomb is then coated with the catalyst coating solution using a dip-coating method.
Following this, excess catalyst coating solution is removed via air blowing, and the weight is measured again to verify the exact amount of catalyst coating solution applied to the ceramic honeycomb. Once the coating is complete, the product is dried in a drying oven and then undergoes calcination in a furnace. The calcination process is conducted at temperatures of 450°C or higher. It removes impurities and nitrate components present in the washcoat. The distilled water, acetic acid, octyl alcohol, and MEA are eliminated during the drying and calcination processes. The palladium nitrate and rhodium nitrate contained in the catalyst coating solution undergo chemical reactions through thermal decomposition and oxidation during the calcination process. During this step, the nitrate components (NO3-) undergo thermal decomposition and are removed in the form of nitrogen dioxide (NO2) and oxygen (O2), while palladium and rhodium are converted into palladium oxide (PdO) and rhodium oxide (Rh2O3), respectively, becoming fixed onto the washcoat. The calcination process also enhances the adhesion between the ceramic honeycomb and the catalyst coating layer, preventing the catalyst from detaching during vehicle operation. After the drying and calcination processes, the final weight of the ceramic honeycomb catalyst is measured to confirm the total catalyst coating amount, after which the product is packaged and shipped. You state that the ceramic honeycomb catalyst is imported in bulk containers rather than retail containers. It is packaged in cartons of six pieces each, loaded and exported on a pallet unit, and is used as an industrial part introduced into the catalytic converter manufacturing process of your U.S. buyer, rather than a retail product sold directly to end consumers. Due to the characteristics of the coated surface and spatial constraints for marking, the country of origin is not marked directly on the product itself. Instead, it is scheduled to be printed and indicated on the label of the outer packaging (carton box). In addition, when loading on a pallet unit, a separate label will be attached to indicate the country of origin along with the product specifications, PO number, and batch number. The submitted sample label on the carton box shows the name of the company, product specifications, the number of pieces per box, box number, and the wording “Made in Korea.” The submitted sample label on the pallet indicates the pallet number, product specifications, PO number, batch number, and the phrase “CLEANSKY, Korea.” Country of Origin: 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). In determining whether a substantial transformation occurs in the manufacture of products from chemicals, Customs has consistently examined whether a chemical reaction occurs when two or more chemicals are mixed in the production of the final article. In this case, the raw materials for the washcoat from different countries are mixed in South Korea to complete the catalyst coating solution. The catalyst coating solution is coated on the ceramic honeycomb, and the product then undergoes the drying and calcination processes. The calcination process results in chemical reactions that form a catalyst coating layer where precious metals are impregnated into the washcoat, thereby completing the catalyst component. The catalyst coating layer is the actual area in the catalytic converter where the exhaust gas purification reaction occurs. The active precious metals, such as palladium and rhodium, act as catalysts and serve to convert pollutants, such as carbon monoxide in automotive exhaust gas into substances that are less harmful to the human body and the environment. The calcination process also adheres the washcoat to the ceramic honeycomb substrate,
preventing the catalyst from detaching during vehicle operation. The mixing, coating, drying, and calcination processes substantially transform the raw materials into a new product with a new name, character, and use. Furthermore, the important materials, palladium nitrate and rhodium nitrate, are sourced from South Korea and represent more than 80 percent of the material costs. Given that these manufacturing processes occur in South Korea, the country of origin of the ceramic honeycomb catalyst is South Korea. Marking: The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article. In this case, the ultimate purchaser of the imported ceramic honeycomb catalyst is the U.S. buyer that receives the catalyst in its imported form for incorporation into the catalytic converter. As provided in section 134.41(b), Customs and Border Protection (CBP) Regulations (19 CFR 134.41(b)), the country of origin marking is considered conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read it without strain. With regard to the permanency of a marking, section 134.41(a), CBP Regulations (19 CFR 134.41(a)), provides that as a general rule marking requirements are best met by marking worked into the article at the time of manufacture. For example, it is suggested that the country of origin on metal articles be die sunk, molded in, or etched. However, section 134.44, CBP Regulations (19 CFR 134.44), generally provides that any marking that is sufficiently permanent so that it will remain on the article until it reaches the ultimate purchaser unless deliberately removed is acceptable. Section 134.22, CBP Regulations (19 CFR 134.22), provides general rules for marking of containers or holders. Pursuant to 19 CFR 134.22(a), which governs contents excepted from marking, the regulation states that: [w]hen an article is excepted from the marking requirements by subpart D of this part, the outermost container or holder in which the article ordinarily reaches the ultimate purchaser shall be marked to indicate the country of origin of the article whether or not the article is marked to indicate its country of origin. Section 134.32 under subpart D of Part 134 provides general exceptions to marking requirements for articles meeting certain conditions set forth in the section. Under 19 CFR 134.32(a), imported articles that are incapable of being marked are exempt from individual country-of-origin marking requirements. Under 19 CFR 134.32(d), an imported article is exempt from individual country-of-origin marking if the marking on its container reasonably indicates the article's origin. In this case, the imported product is not for retail sale to end consumers. It is sold to your U.S. buyer directly in bulk carton boxes for incorporation into a catalytic converter as an industrial part. You state that due to the characteristics of the coated surface and spatial constraints for marking, the country of origin is not marked directly on the product itself. Instead, the outer carton box will be marked with the country of origin of the product. Given these facts, we find that the proposed marking on the carton box is acceptable, provided that the label remains on the container until it reaches the ultimate purchaser unless deliberately removed. 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. 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 Fei Chen at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division