N358408

N358408 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 a bond paper roll and bond paper flat pack 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 a bond paper roll and bond paper flat pack for purposes of trade remedy applicability. Product information and samples were provided for our review. The first product under consideration is a bond paper roll. You describe a scenario wherein uncoated bond paper jumbo rolls are manufactured in Indonesia. The jumbo rolls are then shipped to China where they are unrolled, printed on the back with company information and a logo, re-rolled, and then slit into receipt size rolls. The rolls are then packaged and shipped to the United States. The second product under consideration is identified as “bond paper flat pack”. This product is a pad of guest checks for taking orders at restaurants. You describe a scenario wherein uncoated bond paper jumbo rolls are manufactured in Indonesia. The rolls are then shipped to China, where they are unwound and printed. The paper is printed in multiple colors. It is printed at the top with “Guest Check” and printed with fields for date, table, guests, server, lines for ordered items, and a column for amounts. The perforated bottom portion of the form is printed with a guest receipt with date, amount, number of guests, and number of the guest check. On the back, the form is a continuation of the fields on the front. In China, the paper is also cut to size, printed with guest check numbers, perforated near the top edge, and bound into a pad. The finished sample pad measures approximately 3.5” x 6.5” and contains 47 guest checks. 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). For the bond paper roll, the jumbo roll is manufactured in Indonesia. The printing on the back of the paper is not a substantial transformation as it does not impede the paper’s use for receipts or other printing. Cutting the jumbo rolls to size is also not a substantial transformation. Therefore, the country of origin for the bond paper roll is Indonesia. For the “bond paper flat pack”, the jumbo paper roll is manufactured in Indonesia. The printing and perforation transform the base paper into guest checks with a specific designated use and a new name – a business form. A substantial transformation takes place in China. Therefore, the country of origin for the “bond paper flat pack”, i.e., the pads of guest checks, 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). For the bond paper roll, the jumbo roll is manufactured in Indonesia. The printing on the back of the paper is not a substantial transformation as it does not impede the paper’s use for receipts or other printing. Cutting the jumbo rolls to size is also not a substantial transformation. Therefore, the country of origin for the bond paper roll is Indonesia. For the “bond paper flat pack”, the jumbo paper roll is manufactured in Indonesia. The printing and perforation transform the base paper into guest checks with a specific designated use and a new name – a business form. A substantial transformation takes place in China. Therefore, the country of origin for the “bond paper flat pack”, i.e., the pads of guest checks, 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 requ