A country of origin determination on exam table paper

N345915 February 26, 2025 OT:RR:NC:4:434 CATEGORY: Origin Bryan Shields NuCare LLC 4201 Sierra Point Drive, Suite 102Sacramento, CA 95834 RE:      A country of origin determination on exam table paper Dear Mr. Shields: In your letter, dated February 23, 2024, you requested a country of origin ruling.  A detailed description of the exam table paper and the manufacturing operations were submitted for our review. The subject articles are rolls of non-sterile, disposable paper used to protect exam tables and other surfaces in medical and veterinary settings. They will come in widths of 8”, 18” and 24” and lengths of 125’ to 225’. Twelve one-ply rolls are packaged together.  Per your submission, the bulk rolls of paper are manufactured in Indonesia.  You describe the paper as White paper: virgin; with 21 GSM.  These rolls of paper, which measure 8" to 24" in width and have a maximum roll diameter 71mm, with a core diameter of 41mm, are then sent to China, where they are cut to length and then re-rolled onto smaller Chinese-origin cardboard tubes for the individual selling units.  Pursuant to Part 134, Customs Regulations (19 C.F.R. 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304.  Section 134.1(b), Customs Regulations (19 C.F.R. 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 this part.”  A substantial transformation occurs when an article emerges from a process with a new name, character or use different from that possessed by the article prior to processing.  A substantial transformation will not result from a minor manufacturing or combining process that leaves the identity of the article intact.  See United States v. Gibson-Thomsen Co., 27 C.C.P.A. 267 (1940); and National Juice Products Association v. United States, 628 F. Supp. 978 (Ct. Int’l Trade 1986). You propose that the country of origin is Indonesia.  We agree.  In China the paper does not undergo a substantial transformation resulting in an item with a new name, character or use simply by cutting and packaging.  As support, we reference existing Headquarters ruling 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 exam table paper 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 CFR 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 Charlene S. Miller at charlene.s.miller@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division