The country of origin of planner and to-do list pads

N353312
September 17, 2025
MAR-2-48:OT:RR:NC:N5:130
CATEGORY: Country of Origin Mr. Aiko Zhu Ningbo Johnshen Stationery Co., Ltd No.39, Hengchun Sijili High-tech District, Ningbo, Zhejiang Ningbo, 315040 CHINA RE: The country of origin of planner and to-do list pads Dear Mr. Zhu: In your letter dated August 5, 2025, you requested a binding country of origin ruling on multiple paper pads for the purpose of duty calculation. You filed the request on behalf of your client, Walgreen Co. The request was returned to you for additional information twice. The information was received by this office on September 5, 2025. Product information and photos were provided for our review. The product under consideration is a retail package of three paper pads. The first, measuring 148x210mm, is printed with “Weekly Plan”, is marked with the days of the week and has separate sections for notes. The second, measuring 120x170mm, is printed with “Take Notes” and has a section for notes and a to-do list section. The third, measuring 65x130mm, is printed with “To Do” and has sections for each day of the week. You do not indicate how many sheets are in any of the pads. In your letter, you describe a scenario wherein the base paper and backer board are made in Vietnam. The paper is also printed, cut, assembled, and packaged in Vietnam. 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). All of the manufacturing operations occur in Vietnam. Most importantly, the base paper is made in Vietnam. Therefore, the country of origin for the planner and to-do list pads is Vietnam.

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,
(for) Denise Faingar Acting Director National Commodity Specialist Division