CLA-2-37:OT:RR:NC:2:235
Ms. Penelope Perkins
John S James Co.
4119-F Rose Lake Drive
Charlotte, North Carolina 28217
RE: The tariff classification of Thermal Transfer Ribbon from Japan
Dear Ms. Perkins:
In your letter dated February 16, 2010, you requested a tariff classification ruling.
In your ruling request letter on behalf of DNP IMS America Corp, you indicate the following:
Fist you state that “the item in question is a spool of thermal transfer ribbon which is used in a thermal transfer printer to produce labels for various industrial products, such as electronic parts, chemical drums, and compliance labels for the automotive, steel and apparel industries. The labels require printing that can withstand friction, moisture, rubbing, solvents and heat. These labels most often use a 1 dimensional barcode symbology. The thermal transfer printer, or barcode printer is used in connection with automatic data processing (ADP) software contained in the operator’s PC. The barcode image is printed on various types of media, i.e. paper, clay coated paper or plastic coated paper.”
Next, you further explain that “the spools are manufactured from imported polyethylene terephthalate film coated with thermal transfer “ink” in a Foreign Trade Zone. The ink is not a typical ink, but consists of waxes, resins, and pigments and has a melting point in the range from 60 to 110 degrees Celsius. These thermal ribbons come in three main formulations – wax, wax-resin, or pure resin. These spools are monochrome colors i.e., black, green, blue, red, gold, silver, or any other single color available. This ribbon is imported in “jumbo” rolls to be slit or manufactured in the FTZ.”
Finally, you state “the manufacturing process for these spools is completed by placing the “jumbo” roll on a slitting machine that holds the roll under tension while it is cut into specific widths and lengths. The finished spools range in width from 19 mm up to 273 mm depending on the size of the printer. The ribbon is wrapped around a core, which is typically fiber or plastic, with a trailer that will activate a sensor which will let the printer know when the ribbon is expended. There is a leader on the ribbon to protect it during shipping and facilitate the loading of the ribbon into the printer. The leader is secured with adhesive tape to prevent it from unraveling. These spools are placed into the thermal transfer printer by placing a metal or plastic spindle through the core to hold them in place. The leader is then pulled between the platen roller and thermal print head and manually attached to the ribbon take-up spindle that is part of the printer.”
The applicable subheading for the thermal transfer ribbon if imported in a width not exceeding 105 mm will be 3702.39.0100, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Photographic film in rolls, sensitized, unexposed, of any material other than paper, paperboard or textiles; instant print film in rolls, sensitized, unexposed: Other film, without perforations, of a width not exceeding 105 mm: Other.” The rate of duty will be 3.7% ad valorem.
The applicable subheading for the thermal transfer ribbon if imported in a width exceeding 105 mm will be 3702.44.0160, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Photographic film in rolls, sensitized, unexposed, of any material other than paper, paperboard or textiles; instant print film in rolls, sensitized, unexposed: Other film, without perforations, of a width exceeding 105 mm: Of a width exceeding 105 mm but not exceeding
610 mm: Other.” The rate of duty will be 3.7% ad valorem.
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 on World Wide Web at http://www.usitc.gov/tata/hts/.
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Paul Hodgkiss at (646) 733-3046.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division