CLA-2-48:OT:RR:NC:N5:130
Ms. Deana Smith
The William Carter Company
3438 Peachtree Rd.
Atlanta, GA 30326
RE: The tariff classification of paper packaging components and a registration card from Cambodia or China.
Dear Ms. Smith:
In your letter, dated March 24, 2025, you requested a binding tariff classification ruling on paper packaging
components and a registration card. Product information and photos were submitted for our review.
Item 1 is a die-cut label printed with product information about a plastic baby tub. The label is made from
e-flute cardboard (a variety of thin corrugated cardboard), is printed (not lithographically) with five-color
print, and is laminated with a matte plastic film. The label is printed on both sides with pictures, usage and
safety information, and more. After importation, the label will be applied to the tub for retail sale.
Items 2 and 4 are structural cardboard inserts. One is a strip of corrugated cardboard that is folded into a
triangle and taped into shape. The second is a strip of corrugated cardboard that is folded into a rectangle and
taped into shape. The inserts appear to function as spacers between the product and label or other items.
Item 3 is a printed registration card. The card is inkjet-printed and is to be filled out by the consumer and
returned to the manufacturer after retail purchase. The card is scored for folding in half and is printed on one
side with spaces for the consumer to complete with their personal and product information. The other side is
pre-addressed and postage-paid for convenient return.
Item 1 is a paperboard label. Labels are provided for in heading 4821 of the Harmonized Tariff Schedule of
the United States (HTSUS). In understanding the language of the HTSUS, the Explanatory Notes to the
Harmonized System (ENs) may be utilized. The ENs, although not dispositive nor legally binding, provide a
commentary on the scope of each heading of the HTSUS, and are the official interpretation of the
Harmonized System at the international level. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989).
The ENs to heading 4821 define labels as “…used for attachment to any type of article for the purpose of
indicating its nature, identity, ownership, destination, price, etc. They may be of the stick-on type (gummed
or self-adhesive) or designed to be affixed by other means, e.g., string.” The label clearly identifies the
product and relevant information about the product specifically for the use of a consumer. It is not
immediately clear how the label attaches to the baby tub after importation, but it is clear that the label
communicates information about the product. Therefore, the label is classifiable in heading 4821.
The applicable subheading for the printed paper label will be 4821.10.4000, HTSUS, which provides for
Paper and paperboard labels of all kinds, whether or not printed: Printed: Other. The rate of duty will be free.
The structural cardboard inserts are manufactured articles that are functional in the packaging of a baby tub.
They are made from corrugated cardboard that has been folded and taped into shape. These are not
specifically provided for in any heading of chapter 48.
The applicable subheading for the structural cardboard inserts will be 4823.90.8680, HTSUS, which provides
for Other paper, paperboard, cellulose wadding and webs of cellulose fibers, cut to size or shape; other
articles of paper pulp, paper, paperboard, cellulose wadding or webs of cellulose fibers: Other: Other: Other:
Other: Other: Other. The rate of duty will be free.
You suggest that the registration cards are classifiable in heading 4823 as other articles of paper. However,
the ENs explain that Chapter 49 “covers all printed matter of which the essential nature and use is determined
by the fact of its being printed with motifs, characters or pictorial representations.” The information printed
on the registration card provides the essential nature and use of the cards. Therefore, they are classifiable in
Chapter 49. See rulings HQ953472, N005873, and B81338.
The applicable subheading for the registration cards will be 4907.00.0000, HTSUS, which provides for
Unused postage, revenue or similar stamps of current or new issue in the country in which they have, or will
have, a recognized face value; stamp-impressed paper; banknotes; check forms; stock, share or bond
certificates and similar documents of title. The rate of duty will be free.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheadings 4821.10.4000, 4823.90.8680, and 4907.00.0000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 4821.10.4000 or 4823.90.8680, HTSUS, unless specifically excluded, are subject to an
additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99
subheading, i.e., 9903.88.03, in addition to subheading 4821.10.4000 or 4823.90.8680, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 4907.00.0000, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you mush report the Chapter 99 subheading, i.e.,
9903.88.15, in additional to subheading 4907.00.0000, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
At the time of this letter, these duties do not apply to imports from Cambodia.
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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division