The country of origin of thermal paper rolls

N363986August 14, 2026MAR-2-48:OT:RR:NC:N5:130
CATEGORY:Country of Origin Mr. Jiang QiuSynergistics LLC22561 Naugatuck SqAshburn, VA 20148 RE:The country of origin of thermal paper rolls Dear Mr. Qiu:In your letter, dated
August 4, 2026
, you requested a binding country of origin ruling on behalf of your client,Dongguan SunStar Paper Co., Ltd.The ruling was requested on rolls of thermal paper.Product information was submitted for our review. You outline a scenario wherein jumbo rolls of thermal paper are manufactured in Indonesia and are then sentto China, where they are slit into register-size rolls, printed on the back side with brand information, andpackaged.When determining the country of origin for purposes of applying current trade remedies under Section 301and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters RulingLetter H301619, dated November 6, 2018. The test for determining whether a substantial transformation willoccur is whether an article emerges from a process with a new name, character, or use different from thatpossessed by the article prior to processing. See , 681 F.2d 778Texas Instruments Inc. v. United States(C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v., 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).United StatesThe substantial transformation occurs when the thermal paper is manufactured.The slitting into smaller rolls does not change the thermal paper to a new and different product.Therefore, the country of origin of the thermal paper will be Indonesia.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to theclassification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated CargoSystems Messaging Service (CSMS) messages at and the Trade Remedies page at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service.https://www.cbp.gov/trade/programs-administration/trade-remediesThe holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Laurel Duvall at [email protected]
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division