OT:RR:NC:N4:434
Jiang Qiu
Synergistics LLC
22561 Naugatuck Sq
Ashburn, VA 20148
RE: The country of origin of paper towel sheets and rolls
Dear Mr. Qiu:
In your letter dated January 26, 2026, you requested a country of origin ruling on behalf of your client, Green
Planet Paper Co., Ltd, for the purpose of duty calculation and Section 301 applicability. Photos and a
detailed description of the manufacturing operations were provided for our review.
The paper products under consideration are “folded paper towel,” “paper towel roll,” and “kitchen towel.”
They come in either single or double ply with 1/2-fold, 1/3-fold, C-fold, or in rolls.
Per your submission, the bulk rolls of paper stock are manufactured in Indonesia. You indicate the tissue
paper used to produce the paper towel products are white or brown in color, 100% wood pulp produced from
virgin fiber; layer:1-2; 20-32 grams per square meter. These parent rolls of paper, which measure in multiple
widths from approximately 1160mm up to 2840mm and have a maximum roll diameter of approximately
1500mm, are then sent to China, where the paper is unwound, embossed, then either cut and fold to length
and width or rewound and cut for rolls. The paper towels are then 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 paper towel stock does not undergo a substantial transformation resulting in an item with a new
name, character or use simply by unwinding, embossing, cutting, rewinding or folding and packaging.
As support, we reference 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 folded paper towel, paper towel roll, and kitchen towel 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 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 Susana Li at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division