OT:RR:NC:N5:130
Richard Writsman
Continental Agency Inc
1768 W Second Street
Pomona, CA 91766
RE: The country of origin of toilet seat covers
Dear Mr. Writsman:
In your letter dated June 23, 2025, you requested a country of origin ruling on behalf of your client, Jinan
Hehe Paper Co., Ltd., for the purpose of duty calculation and Section 301 applicability. A detailed
description of the manufacturing operations and samples were provided for our review.
The paper products under consideration are toilet seat covers. Per your submission, bulk rolls of toilet seat
cover tissue are manufactured in Indonesia. You describe the toilet seat covers as white/kraft paper: virgin;
layer: 1;14 g/sm. These parent rolls of toilet seat cover tissue, which measure 360mm in width and have a
maximum roll diameter 360mm, are then sent to China, where the tissue paper is embossed, folded, cut to
size and sometimes octagonal shape, 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 tissue paper does not undergo a substantial transformation resulting in an item with a new name,
character or use simply by embossing, folding, cutting, and packaging. The tissue paper is specifically
dedicated for use as toilet seat covers and does not change into a new and different product by its working.
As support, we reference existing Headquarters Ruling Letter (HQ) W967997, dated October 5, 2006, in
which the processes of printing, cutting and folding tissue paper in a second country did not result in a
substantial transformation. Likewise, in HQ 557462, dated September 13, 1994, the operations of cutting and
folding were found to be merely finishing operations, which, again, did not constitute a substantial
transformation.
The country of origin of the finished toilet seat covers 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 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 Laurel Duvall at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division