The country of origin of a printed laminated plastic sheet

N352938
September 8, 2025
OT:RR:NC:N5:137
CATEGORY: Origin Jada Fox Energizer Holdings Inc. 8235 Forsyth Boulevard, Suite 100 St. Louis, MO 63124 RE: The country of origin of a printed laminated plastic sheet Dear Ms. Fox: In your letter dated August 26, 2025, you requested a country of origin ruling on a printed, laminated plastic sheet. PETG film Manufacturing steps in China: Polyethylene terephthalate glycol (PETG) chips are produced. The PETG chips are melted, extruded and stretched to create PETG shrink film. The PETG film is placed onto rolls. BoPET/Aluminum sheet Manufacturing steps in China: Chinese origin Biaxially Oriented Polyethylene Terephthalate (BoPET) film is coated with silicon release emulsion to produce the release film. The release film is adhered to an aluminum film of Chinese origin with Chinese origin glue to create the BoPET/Aluminum sheet. The BoPET/Aluminum sheet is placed onto rolls. The rolls of PETG shrink film and the BoPET/Aluminum sheet are shipped from China to Thailand Manufacturing steps in Thailand: The Chinese origin PETG film is printed. The printed Chinese origin PETG film is adhered to the Chinese origin BoPET/Aluminum sheet using Chinese glue to create the printed, laminated plastic sheet. The printed, laminated plastic sheet is split into small, narrow rolls. The narrow rolls of laminated plastic sheet are cut into individual labels that can be applied to primary battery cells. The labels are inspected, counted, and packaged for shipment.

When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter 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 steps performed in Thailand: combining two Chinese origin sheets into a laminated sheet, cutting to size and packaging, constitute minor processing and do not result in a substantial transformation. Therefore, the country-of-origin of the finished printed laminated plastic sheet remains 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 Christina Allen at [email protected].
Sincerely,
(for) Denise Faingar Acting Director National Commodity Specialist Division