The country of origin of paper labels

N358405 February 11, 2026 MAR-2-48:OT:RR:NC:N5:130 CATEGORY: Country of Origin Mr. Richard Writsman Continental Agency Inc. 1768 W Second St. Pomona, CA 91766 RE: The country of origin of paper labels Dear Mr. Writsman: In your letter, dated December 17, 2025, you requested a binding country of origin ruling on behalf of your client, Lopie International (HK) Limited. The request was returned to you for additional information, which was received by this office on January 31, 2026. The ruling was requested on labels for purposes of trade remedy applicability. Product information and samples were provided for our review. The merchandise under consideration is rolls of self-adhesive paper labels. You describe a scenario wherein the jumbo rolls of thermal or uncoated paper are manufactured in Indonesia. The rolls are shipped to China where the paper is cut to shape (rectangles with rounded corners), coated with adhesive, laminated to a sheet of release paper, printed with solid color or a colored company logo, and packaged. When determining the country of origin for purposes of applying duty rates, 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). The jumbo rolls of thermal and uncoated paper are manufactured in Indonesia. Cutting the paper to shape, coating it with adhesive, and laminating it to release paper results in a substantial transformation. The thermal or uncoated paper from Indonesia is transformed into labels in China. The resulting item has a different name, character, and use than the original thermal or uncoated paper. Therefore, the country of origin of the labels is China. IEEPA reciprocal duties will apply for China. 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 laurel.duvall@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division