CLA-2-37:OT:RR:NC:N1:135

Ms. Laura Lyons
Electronics for Imaging (EFI), Inc.
6750 Dumbarton Circle
Fremont, CA 94555

RE: The tariff classification of thermal transfer ribbons from Spain and other countries.

Dear Ms. Lyons:

In your letter dated March 7, 2018, you requested a tariff classification ruling. Two samples received from the previous correspondence were examined and disposed of.

You state thermal transfer ribbons come in a variety of single colors with a variety of widths and their use is dependent upon the specific print machine being utilized. Two representative samples were provided. Samples AR12SIR50 and AR36PM15 are two colored thermal transfer ribbons wound on two core rolls. Two notches were cut out on each end of each roll. You explain that “[t]he notches are cut to fit into a hub on each side of the printer with a pin. This hub turns when the printer is printing, allowing the ribbon to turn without slipping. The ribbon transfers onto various substrates through a small amount of heat created from a thermal printhead. That printhead fires ‘dots’ of data, creating the image.”

Sample AR12SIR50 is a red color (monochrome) thermal transfer ribbon measuring 317 millimeters in width and 500 meters in length. It is only used on the DTS-12 Digital Traffic Sign Printer. Sample AR36PM15 is a magenta color (monochrome) thermal transfer ribbon measuring 914 millimeters in width and only used on the DTS-36 Digital Traffic Sign Printer. A representative Material Safety Data Sheet indicates that the ribbons consist of inks (color pigments), modified hydrocarbon waxes, synthetic waxes, and EVA copolymer coated on plastic film (polyethylene terephthalate).

The applicable subheading for Sample AR36PM15, if its length exceeds 200 meters, will be 3702.42.0100, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Photographic film in rolls, sensitized, unexposed, of any material other than paper, paperboard or textiles … Other film, without perforations, of a width exceeding 105 mm … Of a width exceeding 610 mm and of a length exceeding 200 m, other than for color photography.” The general rate of duty will be 3.7 percent ad valorem.

If its length does not exceed 200 meters, the applicable subheading for Sample AR36PM15 will be 3702.43.0100, HTSUS, which provides for “Photographic film in rolls, sensitized, unexposed, of any material other than paper, paperboard or textiles … Other film, without perforations, of a width exceeding 105 mm … Of a width exceeding 610 mm and of a length not exceeding 200 m.” The general rate of duty will be 3.7 percent ad valorem.

The applicable subheading for Sample AR12SIR50 will be 3702.44.0160, HTSUS, which provides for “Photographic film in rolls, sensitized, unexposed, of any material other than paper, paperboard or textiles … Other film, without perforations, of a width exceeding 105 mm … Of a width exceeding 105 mm but not exceeding 610 mm … Other.” The general rate of duty will be 3.7 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 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, contact National Import Specialist Fei Chen at Fei.Chen@cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division