CLA-2-96:OT:RR:NC:N4:462
Julia Rhodes
Kleen Slate Concepts LP
14997 Camage Avenue, Unit B
Sonora, CA 95370
RE: The tariff classification of hard dry erase pockets and sleeves from China
Dear Ms. Rhodes:
In your letter dated May 5, 2020, you requested a tariff classification ruling. Images of two items were submitted in lieu of samples.
The items under consideration are described as follows:
Item 1, the “KleenSlate Dry Erase Pockets,” are made of clear polymerizing vinyl chloride (PVC) in the front with a solid hard back made of polypropylene and measure 13 ½” x 10 ½”. They are designed to store and protect several documents in the clear pocket, enabling the user to switch out worksheets or activities. The student writes on the surface of the PVC front, which can be wiped off and used again. The four colors of edge stitching allow the teacher to color coordinate lessons. They also include an elastic loop that is sewn into the stitching to hold a dry erase marker.
Item 2, the “KleenSlate Dry Erase Sleeves,” are pockets formed of PVC clear plastic sheeting that have been sewn around three edges and open to the right side. They measure approximately 10” x 8” and adhere, by means of three adhesive strips, to a hard plastic dry erase paddle. The paddle is imported separately. One paper template, with lines on one side and a graph on the opposite side, is included with each sleeve. The student will place the template into the sleeve or use a custom template provided by the teacher. The student writes on the surface of the PVC sleeve, which can be wiped off and used again. The six colors of edge stitching allow the teacher to color coordinate lessons.
The PVC sleeves with paper templates constitute a composite article within the meaning of the General Rules of Interpretation (GRI) 3(b). It is the PVC sleeve that imparts the essential character.
The applicable subheading for item 1, “KleenSlate Dry Erase Pockets” will be 9610.00.0000, Harmonized Tariff Schedule of the United States, (HTSUS), which provides for “slates and boards, with writing or drawing surfaces, whether or not framed.” The rate of duty will be 3.5 percent ad valorem.
The applicable subheading for item 2, the “KleenSlate Dry Erase Sleeves” will be 3926.10.0000, HTSUS, which provides for “Office or school supplies,” of plastic. The rate of duty will be 5.3 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 the World Wide Web at https://hts.usitc.gov/current.
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, please contact National Import Specialist Sandra Sary at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division