N360064

N360064 April 20, 2026 OT:RR:NC::N4:422 CATEGORY: Classification; Origin TARIFF NO.: 7615.10.7125 Mr. Jerry Gao LEAF Environmental Products Inc. 431 Manitou Road SE Calgary T2G 4C2 Canada RE: The classification and country of origin of three round disposable aluminum foil trays Dear Mr. Gao: In your letter dated March 18, 2026, you requested a classification and country origin ruling on three round disposable aluminum foil trays. Product descriptions and a photograph were submitted for our review. Please note, this letter is part of a split ruling. The disposable aluminum foil rolls and pop-up sheets were addressed in New York Ruling N359812. The disposable aluminum foil trays will be addressed herein. The merchandise under consideration are three disposable aluminum foil trays made of 100 percent non-alloy aluminum foil with a thickness ranging approximately from 0.050 to 0.070 millimeter (mm). They are available in three sizes: 7-inch trays (item # 645301), 8-inch trays (item # 645318), and 9-inch trays (item # 645325). Per your correspondence, the disposable aluminum foil trays are imported empty and do not include lids. They are imported as standalone aluminum trays. Each item will be sold in a quantity of 500 per case. The articles will be used for food service preparation and use, including cooking, baking, storage, and serving food. Classification You propose classification of the three round disposable aluminum foil trays in subheading 7615.10.90. We disagree. This subheading is incorrect and does not exist. The applicable subheading for the three round disposable aluminum foil trays, 7-inch trays (item # 645301), 8-inch trays (item # 645318), and 9-inch trays (item # 645325), will be 7615.10.7125, Harmonized Tariff Schedule of the Unites States (HTSUS), which provides for “Table, kitchen or other household articles and parts thereof, of aluminum…: table, kitchen or other household articles and parts thereof…other: cooking and kitchen ware: not enameled or glazed and not containing nonstick interior finishes: other…containers suitable for food preparation, baking, reheating or storage, 0.04 mm or more but not over 0.22 mm in thickness.” The general rate of duty will be 3.1 percent ad valorem. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. Country of Origin In your request, you stated that the raw material, aluminum, is sourced from Indonesia. The entire production processes are performed in Indonesia as follows: 1. Aluminum foil jumbo rolls are received from an upstream supplier. 2. The foil is loaded onto a decoiling machine. 3. The foil is fed into a mechanical press. 4. The press punches and forms the aluminum into the shape of the tray using a die. 5. Excess material is trimmed during the forming process. 6. The formed trays are collected and inspected for quality. 7. Finished trays are stacked, counted, and packed into cartons for export. 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 on the facts you have submitted regarding the production of the three round disposable aluminum foil trays, the country of origin is Indonesia. 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 f iled at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Dana L. Giammanco at dana.l.giammanco@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division

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 on the facts you have submitted regarding the production of the three round disposable aluminum foil trays, the country of origin is Indonesia. 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 f iled at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Dana L. Giammanco at dana.l.giammanco@cbp.