CLA-2-48:OT:RR:NC:CEE008:N4:434
Kathy Sheehan
Office Depot
6600 North Military Trail
Boca Raton, FL 33496
RE: The tariff classification and country of origin of envelopes
Dear Ms. Sheehan:
In your letter dated September 8, 2026, you requested a tariff classification and country of origin
determination ruling for four envelopes. Samples and product information were submitted for our review.
The first item under consideration is a brown, kraft paper envelope, SKU number 330808. The envelope
measures 9 inches by 12 inches and features a gummed flap with a metal clasp for closure. The second item
is a brown, kraft paper envelope, SKU number 683244. The envelope measures 9 inches by 12 inches and
features an adhesive peel-off strip flap for closure. The third item is a white, wove paper envelope, SKU
number 331072. The envelope measures 10 inches by 13 inches and features a gummed flap closure. The
fourth item is a white, wove paper envelope, SKU number 680049. The envelope measures 9 inches by 12
inches and features printed patterns on the inside of the envelope for privacy of content, along with an
adhesive peel-off strip flap for closure.
The applicable subheading for the envelopes will be 4817.10.0000, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for Envelopes, letter cards, plain postcards and correspondence
cards, of paper or paperboard; boxes, pouches, wallets and writing compendiums, of paper or paperboard,
containing an assortment of paper stationery: Envelopes. The general rate of duty will be Free.
The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience
and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided
at https://hts.usitc.gov/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
You outline a scenario wherein brown kraft paper and white wove paper from China are sent to Vietnam,
where the paper is printed (for SKU 680049 only), cut to shape, folded, and glued to form the envelopes with
the corresponding types of closure (metal clasp, gummed flap, or adhesive with release strip). The envelopes
are then packaged in boxes produced in Vietnam.
When determining the country of origin for the purpose of applying current trade remedies and other duties,
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).
Section 134.1(b) of the Customs Regulations (19 CFR 134.1(b)) provides that the "[c]ountry of origin" means
the country of manufacture, production or growth of any article of foreign origin entering the United States.
Further work or material added to an article in another country must effect a substantial transformation in
order to render such other country the "country of origin" within the meaning of Part 134, Customs
Regulations (19 CFR Part 134). Substantial transformation requires that "[t]here must be a transformation; a
new and different article must emerge, ‘having distinctive name, character, or use.’" Anheuser-Busch
Brewing Association v. United States, 207 U.S. 556, 28 S. Ct 204 (1908). We must therefore determine if or
where a substantial transformation of materials occurs in order to determine the country of origin.
Customs has long ruled that the cutting of material to shape constitutes a substantial transformation. Fabric
yardage, for example, is substantially transformed when cut into garment pieces; the country where the
cutting takes place is the country of origin. See HQ rulings 083461 (May 15, 1990), 555189 (June 12, 1989),
554027 (January 13, 1987), 554025 (December 16, 1986), among others. We find that die-cutting the brown
kraft paper and white wove paper into shapes that are ready to be folded into envelopes is analogous to the
cutting to shape of fabric garment pieces. Therefore, the country in which the cutting to shape takes place is
the country of origin.
The country of origin of the completed envelopes is Vietnam.
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 P. Forkan
Director
National Commodity Specialist Division