The country of origin of paper plates

N354397
October 17, 2025
MAR-2-48:OT:RR:NC:N5:130
CATEGORY: Country of Origin Mr. William Yeh Design International Group, Inc. 755 Epperson Dr. City of Industry, CA 91748 RE: The country of origin of paper plates Dear Mr. Yeh: In your letter, dated September 30, 2025, you requested a binding country of origin ruling on paper plates. The ruling was requested for marking purposes. Product information and photos were submitted for our review. In your letter, you outline a scenario wherein jumbo rolls of paper are manufactured in South Korea and sent to China for printing. Subsequently, the rolls of paper are shipped to Taiwan, where they are cut to shape (for example, squared with scalloped edges and octagonal) and molded to three-dimensional form. Finally, packaging and inspection is done in Taiwan. 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). The paper is cut to shape and molded to form in Taiwan. This is a substantial transformation of the base paper into a plate. Therefore, the country of origin is Taiwan. 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division