MAR-2-48:OT:RR:NC:N5:130
Mr. Parth Gupta
RP Paper Impex Private Limited
Jawaharpur Industrial Area, Derabassi
Mohali, Punjab 140507
India
RE: The country of origin and marking of thermal paper
Dear Mr. Gupta:
In your letter, dated January 8, 2026, you requested a binding country of origin and marking ruling on
thermal paper. Product information was provided for our review.
In your letter, you set forth a scenario wherein jumbo rolls of thermal paper are fully manufactured in
Germany. The jumbo rolls are then shipped to India where they are slit into narrow widths for point-of-sale
receipts and other uses. The small rolls are packaged and exported from India.
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 paper are manufactured in Germany. The labor performed in India does not result
in a substantial transformation of the thermal paper. Therefore the country of origin of the small rolls of
thermal paper will be Germany. It is appropriate to mark the small rolls “Made in Germany” or “Product of
Germany” for importation into the United States.
The merchandise in question may be subject to antidumping duties (ADD) for thermal paper from Germany
(A428-850). Written decisions regarding the scope of ADD 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,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division