N358407

N358407 February 27, 2026 MAR-2-48:OT:RR:NC:N5:130 CATEGORY: Country of Origin Mr. Richard Writsman Continental Agency Inc. 1768 W Second St. Pomona, CA 91766 RE: The country of origin of patient sign-in sheets and guest receipts Dear Mr. Writsman: In your letter, dated December 17, 2025, you requested a binding country of origin ruling on behalf of your client, Lopie International (HK) Limited. The ruling was returned to you for additional information, which was received by this office on January 31, 2026. The ruling was requested for patient sign-in sheets and guest receipts for purposes of trade remedy applicability. Product information and samples were provided for our review. The first product under consideration is a printed, carbonless guest receipt. You describe a scenario wherein the carbonless paper and its backing paper are manufactured in Indonesia. The papers are then shipped to China where they are printed on the fronts and backs to be a restaurant order form. The printing creates a business form to take restaurant orders and total the prices due for the meal. There are fields for the server, table number, number of guests, date, ten lines for ordered items, a column for prices charged and several fields at the bottom to total the bill. The back side of the restaurant check has fields to document and total beverages. The paper is cut and the carbonless backing paper is joined by adhesive (laminated) at the top edge. The forms are perforated and printed twice by a second method with a guest receipt number. The finished product is a two-leaf carbonless form measuring approximately 4.25” x 6.5”. The second product under consideration is a carbon paper patient sign-in sheet. You describe a scenario wherein the front paper, carbon paper, and back paper are made in Indonesia. The front sheet is actually a self-adhesive paper on a release paper backing. You do not provide any information about this paper or where the adhesive and release paper are applied. The papers are then shipped to China where the front paper is printed with “Patient Sign-In” and a grid with fields for the patient name, appointment time, arrival time, the doctor to be seen, and other fields. The printing produces a business form to record patient data. The adhesive paper is also cut along the patient lines so that both the line number and the full line of data can be removed and adhered to another piece of paper. The back sheet is printed with the same “Patient Sign-In” information as the front sheet. In China the paper is cut and the front sheet, back sheet, and carbon paper are adhered together with adhesive at the top edge and the pages are perforated approximately 5/8” from the top edge. The finished product is a three-leaf form measuring 8.5” x 11.5”. When determining the country of origin for purposes of applying duty rates, 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). The jumbo rolls of paper are manufactured in Indonesia. The paper is substantially transformed by the printing of the forms in China. The printing, laminating, and perforating, all taken together, transform the original paper into new and different articles – manifold business forms - with specific uses that are significantly different from the base paper. Therefore, the country of origin of the carbonless guest receipt and the patient sign-in form will be China. 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 Laurel Duvall at laurel.duvall@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division 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). The jumbo rolls of paper are manufactured in Indonesia. The paper is substantially transformed by the printing of the forms in China. The printing, laminating, and perforating, all taken together, transform the original paper into new and different articles – manifold business forms - with specific uses that are significantly different from the base paper. Therefore, the country of origin of the carbonless guest receipt and the patient sign-in form will be China. 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 Protecti