MAR-2-48:OT:RR:NC:N5:130
Mr. Steven Shweky
Pets+People Consumer Products, LLC
1407 Broadway
New York, NY 10018
RE: The country of origin of paper plates
Dear Mr. Shweky:
In your letter, dated April 28, 2025, you requested a binding country of origin ruling on paper plates. Product
information and a photo were submitted for our review.
The product under consideration is molded, nesting paper plates. The plates measure 10 inches in diameter,
and the paper from which they are made weighs 300 grams per square meter (gsm). The plates are printed
and molded with an outer rim.
You describe a scenario wherein the master paper rolls are from China. The master paper rolls are sent to
Taiwan, where the paper is cut, printed, and molded into paper plates.
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).
In Taiwan, the paper is die-cut to shape, printed, and molded into the plate shape. The totality of these
operations constitutes a substantial transformation. Therefore, Taiwan is the country of origin of the paper
plates.
You ask whether the shopping bags are subject to antidumping and countervailing duties for paper plates
from China (A570-164, C570-165). Written decisions regarding the scope of antidumping and countervailing
duties (AD/CVD) orders are issued by the Enforcement and Compliance office in the International Trade
Administration of the Department of Commerce (ITA) and are separate from tariff classification and origin
rulings issued by Customs and Border Protection (CBP). General information regarding the ITA and
AD/CVD can be found at https://www.trade.gov/us-antidumping-and-countervailing-duties. The ITA’s
?Guide on How to File for an Antidumping/Countervailing Duty Scope Ruling Request? is available at
https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division