The country of origin of folders

N347189
April 9, 2025
CLA-2-48:OT:RR:NC:N4:434
CATEGORY: Country of Origin Mireya Ruano Veyer LLC. 6600 Military Trail Boca Raton, FL 33496 RE: The country of origin of folders Dear Ms. Ruano: This is in response to your letter dated March 28, 2025, requesting a country of origin determination, for purposes of Section 301 trade remedies, on one style of hanging file folder. Photos and a detailed description of the manufacturing operations were provided for our review. SKU 810994 is a standard hanging file folder consisting of a paper folder with metal rods inserted through the top with hooks on the ends designed to hang in a file cabinet drawer. The folders feature removeable clear plastic tabs with paper inserts for labeling the files. Per your submission, the paper is made in Thailand, where it is die-cut to shape. In Thailand, the full assembly of the paper folder with the metal hook (China-origin) and plastic tab with insert paper (Thai-origin) takes place. When determining the country of origin for purposes of applying current tariffs, including 301 trade remedies, 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 folders (SKU 810994), the country of origin will be Thailand. A substantial transformation took place in Thailand where the paper and metal fasteners are all transformed into a hanging file folder. 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 Charlene S. Miller at [email protected].
Sincerely,
Steven A. Mack Director National Commodity Specialist Division