RE: The country of origin of wrapping paper

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 N365375 October 9, 2026 MAR-2-48:OT:RR:NC:N5:130 CATEGORY: Country of Origin Mr. Jiang Qiu Synergistics LLC 22561 Naugatuck Sq Ashburn, VA 20148 RE: The country of origin of wrapping paper Dear Mr. Qiu: In your letter, dated September 24, 2026, you requested a country of origin ruling for your client, Ningbo Feihong Stationery Limited Corporation. The request was for wrapping paper. Product information was submitted for our review. The product under consideration is wrapping paper. You outline a scenario wherein the base paper is fully manufactured in Germany and the paper is printed and foil-laminated in China. Pulp is processed, pulp is manufactured into sheet paper, the paper is coated, surface sized, and calendered, and the paper is finished in Germany. The master rolls are then transported to China, where they are printed with designs, laminated with foil, cut to size, and re-wound and packaged. Section 134.1(b) of the Customs and Border Protection Regulations (19 CFR 134.1(b)) provides that the "[c]ountry of origin" means 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 Part 134, Customs and Border Protection Regulations (19 CFR Part 134). Substantial transformation requires that "[t]here must be a transformation; a new and different article must emerge, ‘having distinctive name, character, or use.’" Anheuser-Busch Brewing Association v. United States, 207 U.S. 556, 28 S. Ct 204 (1908). We must therefore determine where a substantial transformation of materials occurs in order to determine country of origin. The base paper is fully manufactured in Germany. While printing is a significant operation with respect to wrapping paper, the Explanatory Notes to the Harmonized System for Chapter 49 specifically note that, for wrapping paper, the printing is subsidiary to the primary use, i.e., wrapping gifts. The printing in China does not substantially transform the paper into another article with a distinctive name, character, or use. Neither does the application of aluminum foil. Therefore, the country of origin for the wrapping paper is Germany.
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