The country of origin of origin of paper towels

N348872 May 14, 2025 OT:RR:NC:N4:434 CATEGORY: Country of Origin Richard Writsman Continental Agency Inc 1768 W Second St Pomona, CA 91766 RE: The country of origin of origin of paper towels Dear Mr. Writsman: In your letter dated May 9, 2025, you requested a country of origin ruling on behalf of your client, Dongguan Lopie Paper Co., Ltd, 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 paper products under consideration are "paper towels" (hand towel sheet, center-pull towel, hand roll towel and kitchen roll towel). They come in either single, double or triple ply with 1/3 fold, 1/6 fold or no fold. Per your submission, the bulk rolls of paper stock are manufactured in Indonesia. You describe the paper as White/Kraft 100% wood pulp virgin paper; layer:1-2; 17-42g/sm. These parent rolls of tissue paper, which measure in multiple widths from 1300mm up to 2850mm and have a maximum roll diameter of 2850mm, are then sent to China, where the paper is embossed, cut and folded to length and width with no shaping done. The hand towels are then subjected to quality control and packaged. When determining the country of origin for purposes of applying current trade remedies under Section 301, 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 paper towel stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by embossing, cutting, folding and packaging. The country of origin of the finished paper towel 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 Charlene Miller at charlene.s.miller@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division