Ms. Sandra Tovar
500 Lanier Ave., West Suite 901
Fayetteville, GA 30214
RE: The tariff classification of thermal transfer tape and thermal transfer ink rolls
Dear Ms. Tovar:
In your letter dated April 25, 2012, on behalf of Avery Dennison, you requested a tariff classification ruling.
Three samples were provided with your letter. Item A – 1400HSA is described as single-sided heat seal polyurethane thermal transfer tape. The tape is said to be composed of cellular polyurethane film on rolls. It does not contain any textile material and is not self-adhesive. It will be used in the manufacture of labels for footwear and clothing. At the time of importation, it is not printed and it does not contain any wax or ink.
Item B – 10D013050 is described as a thermal transfer ink roll. It is composed of polyethylene terephthalate (PET) film with wax/resin ink applied. The ink roll will be used to imprint information on labeling materials such as paper, plastic or textile. It is used in a thermal transfer printer to transfer ink to the label material. The widths of the rolls will vary and the classification will depend in part upon the width.
Item C – 4800TWT is described as thermal transfer tape of double sided, coated polyester textile. This material will be used for labels used in garments, tracking, size tabs and similar uses. The tape is composed of 100 percent polyester coated on both sides with polyurethane.
You have also requested a classification ruling on labels that will be made with the above materials.
You did not identify the country of origin. The rates of duty provided below are the rates applicable when the products are made in a country with which the United States has Normal Trade Relations.
The applicable subheading for Item A – 1400HSA, the cellular polyurethane thermal transfer tape, will be 3921.13.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other plates, sheets, film, foil and strip, of plastics: cellular: of polyurethanes: other. The general rate of duty will be 4.2 percent ad valorem.
The applicable subheading for Item B – 10D013050, the thermal transfer ink roll, when imported in widths not exceeding 105 millimeters, will be 3702.39.0100, 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 general rate of duty will be 3.7 percent ad valorem.
The applicable subheading for Item B – 10D013050, the thermal transfer ink roll, when imported in widths exceeding 105 millimeters but not exceeding 610 millimeters, will be 3702.44.0160, 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 but not exceeding 610 mm…other. The general rate of duty will be 3.7 percent 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/.
Your inquiry does not provide enough information for us to give a classification ruling on the labels or on Item C – 4800TWT, the thermal transfer tape made of coated polyester. Your request for a classification ruling on the labels should include a sample of the labels in the condition in which they will be imported. Your request for a classification on Item C - 4800TWT, the thermal transfer tape made of coated polyester, should include answers to the following questions:
Your proposed classification in subheading 3921.13.1500 assumes the polyurethane coating material to be a cellular plastic. Please confirm that the PU is cellular, and describe how it was made cellular (e.g., addition of foaming agent, blowing agent, etc.)
Provide the total weight of the imported tape, the weight of the polyester textile fabric and the weight of the polyurethane coating material in g/m².
This item is referred to as “thermal transfer tape” in your letter. Please confirm that item C does not contain any ink.
We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.
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 Joan Mazzola at (646) 733-3023.
Thomas J. Russo
National Commodity Specialist Division