RE: The country of origin, marking, and applicable trade programs for adhesive paper labels

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365207 October 8, 2026 MAR-2-48:OT:RR:NC:N5:130 CATEGORY: Country of Origin; Marking; Trade Programs Mr. ShanShan Liang Liang + Moody, PLLC 2104 Delta Way, Unit 1 Tallahassee, FL 32303 RE: The country of origin, marking, and applicable trade programs for adhesive paper labels Dear Mr. Liang: In your letter, dated September 18, 2026, you requested a binding country of origin, marking, and applicability of trade programs ruling on behalf of your client, Kuresa S.A. The ruling request was for adhesive paper labels. Product information and photos were submitted for our review. The products under consideration are branded, die-cut, self-adhesive labels packaged in envelopes or boxes. In your letter, you outline a scenario wherein 40”-wide rolls of self-adhesive paper originate in China and are shipped to Peru. In Peru, the rolls are slit to letter width, the label paper is die-cut into labels, and label sheets are cut to size and printed on the front and back with branding and SKU artwork and information. The label sheets are then packaged for retail sale. 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 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). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations.
Jumbo rolls of adhesive paper originate in China. The labels are die-cut to shape and printed with SKU and branding information in Peru. The substantial transformation of adhesive-coated paper into branded address labels occurs in Peru. Therefore, the country of origin for determination of Section 301 duties is Peru. General Note 32 (GN32) of the Harmonized Tariff Schedule of the United States (HTSUS) sets forth the criteria for whether a good is originating under the United States-Peru Trade Promotion Agreement Implementation Act: For the purposes of this note, subject to the provisions of subdivisions (c), (d), (m) and (n) thereof, a good imported into the customs territory of the United States is eligible for treatment as an originating good under the terms of this note if— (i) the good is a good wholly obtained or produced entirely in the territory of Peru, the United States, or both; (ii) the good was produced entirely in the territory of Peru, the United States, or both, and— (A) each of the non-originating materials used in the production of the good undergoes an applicable change in tariff classification specified in subdivision (n) of this note; or (B) the good otherwise satisfies any applicable regional value content or other requirements specified in subdivision (n) of this note; and the good satisfies all other applicable requirements of this note; or (iii) the good was produced entirely in the territory of Peru, the United States, or both, exclusively from materials described in subdivision (b)(i) or (b)(ii) of this note. The labels are not wholly obtained in Peru. However, the jumbo rolls of adhesive paper, originating in China, classifiable in heading 4811, HTSUS, do undergo the applicable tariff change set forth in GN32 note (n): “A change to headings 4819 through 4822 from any heading outside that group.” The finished labels are classifiable in heading 4819. Therefore, the labels are originating under the United States-Peru Trade Promotion Agreement Implementation Act and are eligible for treatment as originating goods. Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). The labels may be marked “Made in Peru” or “Product of Peru”, as appropriate. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 P. Forkan Director National Commodity Specialist Division