The country of origin of paper plates

N348329
May 15, 2025
MAR-2-48:OT:RR:NC:N5:130
CATEGORY: Country of Origin Mr. Steven Shweky Pets+People Consumer Products, LLC 1407 Broadway New York, NY 10018 RE: The country of origin of paper plates Dear Mr. Shweky: In your letter, dated April 28, 2025, you requested a binding country of origin ruling on paper plates. Product information and a photo were submitted for our review. The product under consideration is molded, nesting paper plates. The plates measure 10 inches in diameter, and the paper from which they are made weighs 300 grams per square meter (gsm). The plates are printed and molded with an outer rim. You describe a scenario wherein the master paper rolls are from China. The master paper rolls are sent to Taiwan, where the paper is cut, printed, and molded into paper plates. When determining the country of origin, 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). In Taiwan, the paper is die-cut to shape, printed, and molded into the plate shape. The totality of these operations constitutes a substantial transformation. Therefore, Taiwan is the country of origin of the paper plates. You ask whether the shopping bags are subject to antidumping and countervailing duties for paper plates from China (A570-164, C570-165). Written decisions regarding the scope of antidumping and countervailing duties (AD/CVD) orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce (ITA) and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). General information regarding the ITA and AD/CVD can be found at https://www.trade.gov/us-antidumping-and-countervailing-duties. The ITA’s

?Guide on How to File for an Antidumping/Countervailing Duty Scope Ruling Request? is available at https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf 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 [email protected].
Sincerely,
Steven A. Mack Director National Commodity Specialist Division