CLA-2-48:OT:RR:NC:N4:434
Mireya Ruano
Veyer LLC.
6600 Military Trail
Boca Raton, FL 33496
RE: The country of origin of file folders
Dear Ms. Ruano:
This is in response to your letter dated March 28, 2025, requesting a country of origin determination, for
purposes of Section 301, on three styles of paper folders. Photos and a detailed description of the
manufacturing operations were provided for our review.
SKU 543496 is a tabbed, paper fastener folder. Per your submission, the paper and ink are made in Thailand.
The paper is colored and die-cut to shape in Thailand. The assembly also takes place in Thailand, where the
metal fastener (China origin) and tab reinforcement (Thai origin) are added, and the folders are packaged.
SKU 544387 is a tabbed, paper fastener folder with two tabbed divider pages. The paper used to form the
dividers is made in Thailand. The paper used to form the cover is made in China, as well as the metal
fasteners. In Thailand, the paper is die cut to form the cover and dividers, and the folder is assembled,
including securing of the divider pages and metal fasteners.
SKU 810838 is a tabbed paper manila folder. Per your submission, the paper is made in Thailand, where it is
colored, die-cut to chape, folded and packaged.
When determining the country of origin for purposes of applying current tariffs, including 301 trade
remedies, 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).
For all three styles of folders, the country of origin will be Thailand. A substantial transformation takes place
in Thailand, where the bulk of the raw materials, including the majority of the paper, are made. The major
manufacturing steps take place in Thailand, where the paper is die-cut into the folders and additional
components are added.?
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division