MAR-2-48:OT:RR:NC:N5:130
Mr. Jiang Qiu
Synergistics LLC
22561 Naugatuck Sq
Ashburn, VA 20148
RE: The country of origin of wrapping paper
Dear Mr. Qiu:
In your letter, dated September 24, 2026, you requested a country of origin ruling for your client, Ningbo
Feihong Stationery Limited Corporation. The request was for wrapping paper. Product information was
submitted for our review.
The product under consideration is wrapping paper. You outline a scenario wherein the base paper is fully
manufactured in Germany and the paper is printed and foil-laminated in China. Pulp is processed, pulp is
manufactured into sheet paper, the paper is coated, surface sized, and calendered, and the paper is finished in
Germany. The master rolls are then transported to China, where they are printed with designs, laminated
with foil, cut to size, and re-wound and packaged.
Section 134.1(b) of the Customs and Border Protection 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 and Border Protection 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 where a substantial transformation of materials occurs in order to
determine country of origin.
The base paper is fully manufactured in Germany. While printing is a significant operation with respect to
wrapping paper, the Explanatory Notes to the Harmonized System for Chapter 49 specifically note that, for
wrapping paper, the printing is subsidiary to the primary use, i.e., wrapping gifts. The printing in China does
not substantially transform the paper into another article with a distinctive name, character, or use. Neither
does the application of aluminum foil. Therefore, the country of origin for the wrapping paper is Germany.
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.
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)
James P. Forkan
Director
National Commodity Specialist Division