Newly Released CBP HQ Rulings Nov. 17
The Customs Rulings Online Search System (CROSS) was updated on Nov. 17 with the following headquarters rulings (ruling revocations and modifications will be detailed elsewhere in a separate article as they are announced in the Customs Bulletin):
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H354210: Grain Splits of Bovine Crust Leather; Country of Origin for Purposes of Trade Remedies
| Country of Origin: United States |
| Issue: What is the country of origin of the bovine crust leather for purposes of additional trade remedy measures? |
| Item: Kamali Group Incorporated's grain splits of bovine crust leather. The leather is processed in Brazil from wet blue bovine leather produced in the U.S. from American hides. To produce the wet blue whole hides, raw American hides are salted, bated, pickled, and chrome tanned in the U.S. before they are sorted for grading and shipped to the Brazilian company. In Brazil, the hides are shaved to yield a more uniform thickness, retanned to add colors (during which process chemicals are added to make the leather flame-retardant), and fatliquored to achieve desired color and softness. Finally, the hides are vacuum dried and shipped to KGI back in the U.S. After importation, KGI will sell the imported bovine crust leather to a leather finishing manufacturer in the United States who will finish the leather in accordance with the specifications of its customers. |
| Reason: Consistent with previous rulings, CBP finds that the operations performed in Brazil do not substantially transform the wet blue hides from the U.S. The processing in Brazil is cosmetic in nature and akin to finishing operations. |
| Ruling Date: Nov. 12, 2025 |