CLA-2-39:OT:RR:NC:N4:422
Ms. Melissa Lehmann
M.Z. Berger & Co., Inc.
353 Lexington Avenue, 14th Floor
New York, NY 10016
RE: The tariff classification of plastic picture frames from China
Dear Ms. Lehmann:
In your letter dated September 9, 2025, you requested a tariff classification ruling. Photographs and
specification sheets were submitted with your request.
The items are four picture frames referred to as the Ghost selfie, item #GNC-GF-3763, Skeleton hands with
bow, item # GNC-GF-3764, Scalloped frame with skull bow, item #GNC-GF 3769, and Gold snake with
roses, item #GNC-GF 3770. All picture frames are made of resin plastic and have a protective cover on the
front made of a clear plastic sheeting. They are designed to be placed on a flat surface for photographic
display.
Ghost selfie, item #GNC-GF-3763, is a pink rectangular photo frame. On the lower left side of the frame are
two white ghosts. One of the ghosts is holding up a cell phone and taking a selfie with the camera. A black
cardboard insert with an easel is on the back of the plastic frame. The plastic photo frame measures
approximately 6.70 inches high by 9.50 inches wide as measured at its widest points. The frame fits a 6-inch
by 4-inch photograph.
Skeleton hands with bow, item #GNC-GF-3764, is a black round photo frame. A pink plastic bow is located
on top of the frame, and white plastic skeleton hands are on each side of the frame. A black cardboard insert
with an easel is on the back of the plastic frame. The plastic photo frame measures approximately 7.25 inches
high by 6.70 inches wide as measured at its widest points. The frame fits a 4-inch by 5-inch photograph.
Scalloped frame with skull bow, item #GNC-GF-3769, is a white round photo frame with double scalloped
designs. On top of the frame, a black plastic bow with a skeleton skull is attached. A black cardboard insert
with an easel is on the back of the plastic frame. The plastic photo frame measures approximately 8 inches
high by 6 inches wide as measured at its widest points. The frame fits a 4-inch by 6-inch photograph.
Gold snake with roses, item #GNC-GF-3770, is a black square frame with a gold snake and pink and red
roses. A black cardboard insert with an easel is on the back of the plastic frame. The plastic photo frame
measures approximately 7.64 inches high by 6.63 inches wide as measured at its widest points. The frame fits
a 4-inch by 6-inch photograph.
The applicable subheading for the Ghost selfie, item #GNC-GF-3763, Skeleton hands with bow, item #
GNC-GF-3764, Scalloped frame with skull bow, item #GNC-GF 3769, and Gold snake with roses, item
#GNC-GF 3770 will be 3924.90.2000, Harmonized Tariff Schedule of the United States, (HTSUS), which
provides for “Tableware, kitchenware, other household articles and hygienic or toilet articles of plastics:
Other: Picture frames.” The rate of duty will be 3.4 percent ad valorem.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 3924.90.2000, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading
3924.90.2000, HTSUS, listed above.
The tariffs and additional 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/.
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 Dana L. Giammanco at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division