The country of origin of record paper

N358406
February 18, 2026
MAR-2-48:OT:RR:NC:N5:130
CATEGORY: Country of Origin Mr. Richard Writsman Continental Agency Inc. 1768 W Second St. Pomona, CA 91766 RE: The country of origin of record paper Dear Mr. Writsman: In your letter, dated December 17, 2025, you requested a binding country of origin ruling on behalf of your client, Lopie International (HK) Limited. The ruling was requested returned to you for additional information, which was received by this office on January 31, 2026. The ruling was requested for record paper for purposes of trade remedy applicability. Product information and a sample were provided for our review. The merchandise under consideration is a roll of thermal record paper. You describe a scenario wherein thermal paper jumbo rolls are manufactured in Indonesia. The paper is then shipped to China where it is unwound, printed on the back with advertising information, slit into small rolls and packaged. The record paper rolls are then shipped to the United States from China. 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). The jumbo rolls of thermal paper are manufactured in Indonesia. Cutting the paper to size in China does not result in a substantial transformation. Because the printing does not impart the essential nature and use of the register paper, it also does not result in a substantial transformation. Therefore, the country of origin of the record paper will be Indonesia. 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) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division