N357654

N357654March 5, 2026OT:RR:NC:N3:139 CATEGORY: OriginChi Hwan Choi3AC Company, LTD1301, 181, Gasan digital 1-roGeumcheon-gu, Seoul08503Republic of KoreaRE: The country of origin of an impregnated activated carbonDear Mr. Choi:In your letter dated January 9, 2026 , and several subsequent emails, you requested a country of origin rulingon an activated carbon. You state that this particular activated carbon is differentiated from others due to itsability to target certain hazardous gases, specifically formaldehyde, ammonia, and nitrogen dioxide.A basic form of activated carbon, generated from coal is imported into Korea from China. Also in Korea,non-metallic compounds are premixed together at specified ratios using mechanical equipment. After aninbound inspection, the general activated carbon is impregnated with the mixed non-metallic compounds viacoating equipment. Afterwards the impregnated activated carbon is dried and screened for dust before beingpackaged for shipment, after a final quality inspection.Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, everyarticle of foreign origin imported into the United States 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 toindicate to the ultimate purchaser in the United States, the English name of the country of origin of thearticle. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able toknow by an inspection of the marking on the imported goods the country of which the goods is the product.The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, byknowing where the goods were produced, be able to buy or refuse to buy them, if such marking shouldinfluence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940).Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements thecountry of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBPRegulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an articlein another country must effect a substantial transformation in order to render such other country the “countryof origin” within the meaning of the marking laws and regulations.A substantial transformation occurs when, as a result of manufacturing process, a new and different articleemerges, having a distinct name, character or use, which is different from that originally possessed by thearticle 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 your submission, you state as a result of the impregnation process, the non-metallic compounds chemicallybond with the surface of the activated carbon. The CBP Laboratory has independently confirmed that thesetype of chemical reactions do occur and are permanently irreversible. The CBP Laboratory also confirmedthat based on the non-metallic compounds used in the chemical impregnation process, the impregnatedactivated carbon would be able to chemically absorb the specific hazardous gases of formaldehyde, ammoniaand nitrogen dioxide, for which the basic form of activated carbon could not do via physical adsorption.Therefore, as a result of the chemical changes brought on by the impregnation process, a change in characterto the activated carbon has occurred. As a result of its ability to absorb certain targeted hazardous gaseswhich it could not do prior to the impregnation process, a change in use occurred to the activated carbon. Therefore a substantial transformation has occurred and the country of origin of the impregnated activatedcarbon is Korea.You have proposed to mark what is presumed to be the final exterior packaging of the impregnated activatedcarbon with what you state is a permanent sticker indicating “Made in Korea”. We find this proposedmarking acceptable and that the requirements of 19 U.S.C. 1304 and 19 CFR Part 134 have been met.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist John Bobel at john.bobel@cbp.dhs.gov. Sincerely, (for)James ForkanDesignated Official Performing the Duties of the Division DirectorNational Commodity Specialist Division

set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist John Bobel at john.bobel@cbp.dhs.gov.
Sincerely,
(for)James ForkanDesignated Official Performing the Duties of the Division DirectorNational Commodity Specialist Division