4911.10.0040; 4911.10.0080; 4911.99.8000
Ms. Patricia A. Haleman
SMH (US) Inc.
1817 William Penn Way
Lancaster, PA 17604
RE: The tariff classification of printed matter, advertising,
catalogs, paper packaging inserts, plastic stickers and tags,
Dear Ms. Haleman:
In your undated letter received here on August 15, 1995, you
requested a tariff classification ruling. Ten samples, all
associated with the advertising, marketing and packaging of
watches, were submitted and will be retained for reference.
Item 1 is identified as an "instruction sheet for Swatch
watches." It is a 9 3/4" x 15 1/2" sheet of paper (folded into 2"
x 7 3/4" size), printed on both sides with diagrams and text (in a
number of languages) concerning operating instructions, warranty
information, and service center locations. The printing appears to
have been done by a lithographic process.
The applicable subheading for item 1 will be 4911.99.6000,
Harmonized Tariff Schedule of the United States (HTS), which
provides for other (than certain enumerated) printed matter,
printed in whole or in part by a lithographic process. The rate of
duty will be 0.4%.
Item 2 is a paper insert used to line the inside of a display
box used for Swatch watches. It is a 2 1/8" x 9 1/4" strip of
paper with cutouts at each end and a hole in the center. Although
it is printed with a repetitive dot pattern and the word
"automatic," this product is not considered "printed matter," for
Item 3 is a cardboard insert used to line the inside of a
display box used for Flik Flak watches. It is a piece of
paperboard which has been cut, scored, perforated, folded and glued
(to itself) into an article measuring about 2 3/4" x 7". It is
printed with a repetitive dot pattern only.
The applicable subheading for items 2 and 3 will be
4823.90.8500, HTS, which provides for other (non-enumerated) paper
or paperboard, cut to size or shape, and other (non-enumerated)
articles of paper or paperboard. The rate of duty will be 4.8%.
Item 4 is a sheet of four small, flat, pressure-sensitive
plastic stickers, each printed with a cartoon-style figure or
object captioned with the word "flik-flak." All four stickers are
mounted on a single piece of release paper.
The applicable subheading for item 4 will be 3919.90.5060,
HTS, which provides for other (than certain enumerated) self-
adhesive plates, sheets, film, foil, tape, strip and other flat
shapes, of plastics, whether or not in rolls. The rate of duty
will be 5.8%.
Item 5 is a 2 3/8" x 4" staple-bound booklet containing 38
pages printed with instructions, warranty information and service
center listings. A slit in the back cover holds a plastic card,
one side of which is to be filled in with watch case and code
numbers, date of sale, and jeweler's stamp; the other side is
printed with the terms of the watchmaker's guarantee.
The applicable subheading for item 5 will be 4901.99.0092,
HTS, which provides for other (than certain enumerated) printed
books...containing 5 or more pages each, but not more than 48 pages
each (excluding covers). The rate of duty will be free.
Item 6 is a staple-bound, printed paper catalog which
illustrates and describes a particular line of watches. The inside
of the back cover incorporates a pocket which holds numerous loose
paper sheets printed with additional watch illustrations and style
The applicable subheading for item 6 will be 4911.10.0040,
HTS, which provides for printed catalogs, price lists or trade
notices, relating to offers...to sell or rent products of a foreign
country. The rate of duty will be free.
Items 7 and 8 are staple bound publications identified as
"information booklets" used to "tell the story of our brands and to
explain different features or finishes of our watches." While part
of these publications' content consists of informative matter
(e.g., corporate history, discussions of watchmaking technology,
etc.) they are largely promotional in nature.
Item 9 is a "counter card" intended to be placed on a display
counter in a retail store. It is an 8" x 12", double-layered sheet
of paperboard, the face of which is printed with a picture of a
watch accompanied by the caption "RADO," "Switzerland." The back
layer has been perforated and scored to form a fold-out stand.
The applicable subheading for items 7, 8, and 9 will be
4911.10.0080, HTS, which provides for other (non-enumerated)
printed trade advertising material. The rate of duty will be free.
Item 10, identified as a "string tag," is a black plastic tag,
about 1 1/2" square, printed in gold lettering with a brand name
and slogan. A loop of string runs through a hole at one end. The
back of the tag is covered with white paper (much thinner than the
plastic). You state that one of these tags is put on each watch
you sell, and that the suggested selling price and part number is
put on the back of each tag.
The applicable subheading for item 10 will be 4911.99.8000,
HTS, which provides for other (non-enumerated) printed matter. The
rate of duty will be 4.4%.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
Jean F. Maguire
New York Seaport