N351330

N351330 August 6, 2025 OT:RR:NC:N1:128 CATEGORY: Origin Mr. John Schoenig GDLSK LLP 599 Lexington Avenue, Floor 36 New York, NY 10022 RE: The country of origin of quartz surface products. Dear Mr. Schoenig: In your letter dated July 14, 2025, you requested a country of origin ruling on on behalf of your client, Grand Quartz Tech Co., Ltd. The merchandise under consideration is quartz surface products. They are imported as slabs of various sizes, with thicknesses ranging from 1.8 centimeters to 3 centimeters. From the information you provided, natural quartz is mined in either China or India. The quartz is crushed, purified, and then further ground to produce quartz powder and quartz sand. The quartz powder and quartz sand are then shipped to Thailand. In Thailand, the quartz and quartz powder are combined with resin, coloring, a coupling agent, a curing agent, and titanium dioxide. You state that the resin is sourced from China or India, while the remaining components originate from Thailand. These materials are blended so that they are uniformly agglomerated throughout the body of the product. The blended materials are then poured into a mold. After they are molded, the slabs are compressed, heat-cured, trimmed, and polished before being packed for exportation to the United States. 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). With regards to the quartz surface products at issue, the crushed quartz, quartz sand, and resin from China or India lose their individual identities and are substantially transformed in Thailand. The country of origin of the quartz surface products at issue is therefore 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. 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 Nicole Sullivan at nicole.d.sullivan@cbp.dhs.gov. Sincerely, (for) James Forkan Acting 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). With regards to the quartz surface products at issue, the crushed quartz, quartz sand, and resin from China or India lose their individual identities and are substantially transformed in Thailand. The country of origin of the quartz surface products at issue is therefore 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. 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. I