CLA-2-49:OT:RR:NC:4:434
Judy Chi
Jean Cultural and Creative Co., Ltd.
No. 95-6 Baozhong Rd., Xindian District
New Taipei City
Taiwan
RE: A country of origin determination on greeting cards with matching envelopes
Dear Ms. Chi:
In your letter, dated April 15, 2025, you requested a country of origin ruling for the purpose of tariffs and 301
applicability. A detailed description of the greeting card and the manufacturing operations were submitted
for our review in lieu of samples.
The finished good to be imported is a greeting card. Each is imported packaged individually in a cellophane
bag with a matching envelope. You present two scenarios listing the country of manufacture for the raw
materials and the country of manufacture for various components, including the “backfolder” and inner liner
sheet, or “insert,” of the card itself and the envelope with its liner, as well as the country of assembly for the
finished cards and envelopes. You seek a country of origin determination for each scenario.
Card H9 (where “H” indicates a high level of complexity) is a folded paper greeting card (with envelope)
bearing the image of Cinderella’s carriage and the words “Happy Birthday” on the front. The detailed
carriage and horse are separately laser die-cut, printed pieces of paper that have been glued to the face of the
card to provide dimension. The carriage and greeting are embellished with gold foil and a few plastic “gem”
tip-ons. Inside, on the attached insert sheet, is the printed message, “Enjoy and have a happy birthday.”
In this H9 scenario, the manufacturing is described as follows:
In China, the carriage and horse embellishments are die-cut, printed and decorated with hot foil glitter. The
entire envelope is formed, with liner, by cutting, folding, and gluing paper.
In Taiwan, parent rolls of paper are made and then undergo the following manufacturing operations to create
the card: It is cut to size, printed with the underlying design elements (the interior of the carriage) and
greetings, and the card and insert sheet are assembled. Still in Taiwan, the carriage and horse embellishments
are adhered to the face of the card. The “gem” tip-ons are glued to the face of the card. The finished card and
envelope are packaged together for retail sale and packed for international shipping.
Card H10 represents the same Cinderella greeting card, but with different countries of assembly for some
components, as described here:
In China the carriage and horse paper embellishments are made, and the envelopes are made.
In Taiwan, the card is made from the parent roll of paper, of Taiwan origin, by cutting to size, printing with
the underlying design elements (the interior of the carriage) and greetings. The card insert is also cut and
printed with its greeting.
The cards are then sent to China, where the backfolder and insert sheet of the card are assembled, and the
carriage, horse, and plastic gemstone embellishments are adhered to the front. The finished card and envelope
are packaged together for retail sale and packed for international shipping.
When determining the country of origin, 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 H9 The country of origin will be Taiwan. The paper, which is also of Taiwan origin, is substantially
transformed into a greeting card by the process of printing the greetings on the front of the backfolder and
insert. The cutting, folding and assembling of the backfolder and insert also occur in Taiwan. The
manufacture of the envelopes, whether in China or Taiwan, does not affect the country of origin of the
finished product, as the greeting card is the essential character of the set, and the envelope is simply classified
along with the card.
For H10 the country of origin will be Taiwan. The backfolder and insert are cut and printed in Taiwan. The
processes carried out in China are simple assembly processes that do not change the underlying country of
origin. The manufacture of the envelopes, whether in China or Taiwan, does not affect the country of origin
of the finished product, as the greeting card is the essential character of the set, and the envelope is simply
classified along with the card.
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 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, contact National Import Specialist Charlene Miller
[email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division