CBP Revises Origin Ruling on Finished Leather Hides

In the Aug. 19, 2026, Customs Bulletin and Decisions, U.S. Customs and Border Protection is revoking a ruling regarding the country of origin of finished leather hides, effective with respect to goods entered or withdrawn from warehouse for consumption on or after Oct. 18.

The items at issue are bovine leather imported as whole hides that are approximately 45 to 55 square feet each. The leather is mainly sourced from the U.S., Germany, Sweden, Australia, Great Britain, and Brazil. The hides sourced from Brazil are processed there from raw hide to wet-blue state and then shipped to Vietnam to undergo further processing into finished upholstery leather used in the manufacture of furniture.

In ruling NY N310029 CBP determined that the country of origin of the finished leather hides was Vietnam. CBP said the processing operations performed in Vietnam constituted a substantial transformation of the hides from a product suitable for many uses into a product suitable for specific uses. CBP explained that the material that emerges after these processes has lost the identifying characteristics of its constituent material and possesses attributes such as softness or firmness and a desired color that are specifically applicable to given uses and do not exist in the material sourced from Brazil.

However, CBP now finds that the processing in Vietnam is cosmetic in nature and akin to finishing operations, which prior rulings have held do not constitute a substantial transformation. CBP is issuing ruling HQ H355209 to revoke ruling NY N310029 and hold that the country of origin of the finished leather hides is Brazil.

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