The country of origin of napkins

N359789
March 25, 2026
OT:RR:NC:N4:434
CATEGORY: Country of Origin Jiang Qiu Synergistics LLC 22561 Naugatuck Sq Ashburn, VA 20148 RE: The country of origin of napkins Dear Mr. Qiu: In your letter dated March 17, 2026, you requested a country of origin ruling on behalf of your client, ECO Wrap Limited, for the purpose of duty calculation and Section 301 applicability. Photos and a detailed description of the manufacturing operations were provided for our review. The items under consideration are packages of paper napkins, including “beverage napkin,” “lunch napkin,” “dinner napkin,” “tall/low fold napkin,” “off-fold napkin,” and “dispenser napkin.” The finished napkins are produced in various sizes, with widths ranging from approximately 210 mm to 430 mm and lengths ranging from approximately 160 mm to 430 mm. They are manufactured in either single-ply or double-ply, and are folded into 1/4, 1/6, 1/8, and V folds. Per your submission, the parent rolls of napkin stock are manufactured in Indonesia. You describe the paper as white or brown, with pulp produced from virgin or recycled fiber; layer:1-2; 12-21 gram per square meter. These parent rolls of tissue paper, which measure in multiple widths from approximately 210 mm to 1290 mm with a maximum roll diameter of approximately 1150 mm, are then sent to China, where the paper is unwound, embossed/printed, cut, and folded to length and width. No shaping is done. The napkins are then subjected to quality control and packaged. 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 (“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 China, the napkin stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by unwinding, embossing/printing, cutting, folding and packaging.

As support, we reference HQ W967997, dated October 5, 2006, in which the processes of printing, cutting and folding tissue paper in a second country did not result in a substantial transformation. Likewise, in HQ 557462, dated September 13, 1994, the operations of cutting and folding were found to be merely finishing operations, which, again, did not constitute a substantial transformation. The country of origin of the finished napkins is 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 Susana Li at [email protected].
Sincerely,
(for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division