Mr. B. Bahramian
Center for Technology Management, Inc.
202 Halpine Walk Ct.
Rockville, MD 20851

RE: The tariff classification of plastic sheets from China or South Korea

Dear Mr. Bahramian:

In your letter dated July 30, 2014, you requested a tariff classification ruling.

You included samples of three components made of plastics used in constructing illuminated backlit panels such as for house numbers or signs. Part #26.2 is identified as diffusing sheet. You identify the material as Plexiglas, which is poly(methyl methacrylate). The sheets are rigid, rectangular and not further worked. They are available in different sizes but are generally imported in dimensions of 120 cm by 250 cm and then cut to smaller sizes after importation.

Part #26.1 is identified as reflective sheet. It is a flexible white sheet imported in rolls measuring 60 cm or 100 cm in width and in various lengths. You have not identified the polymer comprising the sheet.

Part #28 is identified as plastic numbers. The sample consists of a plastic sheet measuring 85 mm in width by 175 mm in length with a clear numeral on a black background. When these number panels are placed onto the front of a complete assembly, light shining through the clear numerals illuminates the building address.

The applicable subheading for the Plexiglas diffusing sheets will be 3920.51.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other plates, sheets, film, foil and strip, of plastics, noncellular and not reinforced, laminated, supported or similarly combined with other materials: of acrylic polymers: of poly(methyl methacrylate): other. The rate of duty will be 6.5 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

Your inquiry does not provide enough information for us to give a classification ruling on the reflective sheet. Your request for a classification ruling must identify the polymer comprising the sheet. If composed of a copolymer or polymer blend, provide a breakdown by weight of each monomer. If composed of a polyester other than polyethylene terephthalate, indicate whether it is unsaturated or saturated. You have indicated in your request that the material is unknown. However, this office cannot issue a ruling without these details.

You also requested reconsideration of New York Ruling N254739, dated July 24, 2014, which classified the plastic numbers, part #28, in subheading 3926.90.9980, HTSUS, as other articles of plastics, other. You did not propose any alternate classification. Your reconsideration request should include a step-by-step description of the manufacturing process that explains how the black background is created. Specify whether the numeral is formed by means of a printing process. If so, provide details on the printing method. If the contrast between the black material that forms the background and the clear material that forms the numeral is not created by means of printing, explain in detail how the contrast is produced.

When information on the reflective sheet or the plastic numbers is available, you may wish to consider resubmission of your request. 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. Please note that a request for reconsideration of the classification of the plastic numbers in NY N254739 should be sent separately from any request for classification of the reflective sheet.

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 [email protected]


Gwenn Klein Kirschner
National Commodity Specialist Division