Mr. David Prata
OHL International
At CVS Health
Mail Code 1049
1 CVS Drive
Woonsocket, RI 02895

RE: The tariff classification of a plastic strip ribbon from China

Dear Mr. Prata:

In your letter dated June 11, 2015, you requested a tariff classification ruling on behalf of your client, CVS Health. Samples were submitted for our review and will be returned to you, as requested.

Item number 432491-Multi Channel Ribbon consists of four styles of colored, metalized plastic strip in 18 foot lengths. The strip is composed of 70% polypropylene (PP) and 30% polyethylene terephalate (PET). The ribbons measure approximately 10mm in width. The four ribbon styles are wrapped on a single plastic spool and are of the type used for wrapping gifts.

The ribbons, which have straight cut edges and are not further worked, meet the definition of “plates, sheets, film, foil, and strip” as set forth in Note 10 to Chapter 39, Harmonized Tariff Schedule of the United States (HTSUS), which states:

In headings 3920 and 3921, the expression "plates, sheets, film, foil and strip" applies only to plates, sheets, film, foil and strip (other than those of chapter 54) and to blocks of regular geometric shape, whether or not printed or otherwise surface-worked, uncut or cut into rectangles (including squares) but not further worked (even if when so cut they become articles ready for use). In accordance with Note 4 to Chapter 39, HTSUS, because the polypropylene predominates by weight, the ribbon is classified as polypropylene.

The applicable subheading for the plastic strip ribbon will be 3920.20.0015, 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 polymers of propylene: Strip put up in packaging for use as decorative or gift-wrapping ribbon. The rate of duty is 4.2 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

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 Laurel Duvall at [email protected]


Gwenn Klein Kirschner
National Commodity Specialist Division