N364871

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364871 September 22, 2026 CLA-2-42:OT:RR:NC:N4:441 CATEGORY: Classification; Origin TARIFF NO.: 4202.92.9700 Kathy Sheehan Office Depot 6600 North Military Trail Boca Raton, FL 33496 RE: The tariff classification and country of origin of a document case Dear Ms. Sheehan: In your letter dated September 4, 2026, you requested a tariff classification and country of origin ruling. A sample was submitted and will be retained as requested. The article at issue is a document case, SKU 6498070. It is constructed with an outer surface of plastic sheeting sewn over an inner layer comprised of foam, cardboard, and chipboard. The case measures 10.24 inches x 12.99 inches x 0.87 inches and features an open top, three removable plastic dividers, and a magnetic flap closure. We note that the article is sturdy and provides storage, protection, portability, and organization to the intended contents. The applicable subheading for the document case, SKU 6498070, will be 4202.92.9700, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other containers and cases, with outer surface of sheeting of plastic or of textile material, other, other, other, and other. The general rate of duty will be 17.6 percent ad valorem. You have also inquired about the correct country of origin of the product and have provided the list of materials and manufacturing steps outlined below. Materials of Chinese Origin Plastic sheeting rolls Magnet Materials of Korean Origin Cardboard sheets Materials of Malaysian Origin Plastic sheets Chipboard sheets Plastic foam rolls The Chinese and Korean origin materials are shipped to Malaysia. In Malaysia, a slitting machine trims rolls of plastic sheeting to the desired size, while a cutting machine trims the foam rolls and sheets of plastic, cardboard, and chipboard to size. A die-cut mold is used for shaping before the materials are glued, folded, and sewn together. A magnet is added to the flap closure, which is embossed with the brand logo. Section 134.1(b) of the Customs Regulations (19 CFR 134.1(b)) provides that the “[c]ountry of origin” means the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of Part 134, Customs Regulations (19 CFR Part 134). Substantial transformation requires that "[t]here must be a transformation; a new and different article must emerge, ‘having distinctive name, character, or use.’" Anheuser-Busch Brewing Association v. United States, 207 U.S. 556, 28 S. Ct 204 (1908). We must therefore determine if and/or where a substantial transformation of materials occurs in order to determine country of origin. Based on the provided information, it is the opinion of this office that the processes performed in Malaysia create a product with a new name, character and use different from those possessed prior to processing. As such, the country of origin of the document case is Malaysia. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 CFR 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 Vikki Lazaro at vikki.lazaro@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division

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 CFR 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 Vikki Lazaro at vikki.lazaro@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division