CLA-2-48:OT:RR:NC:N5:130
Mr. Raffaele Natale
American Shipping Co., Inc.
250 Moonachie Road
Moonachie, NJ 07074
RE: The tariff classification of paper shopping bags from China
Dear Mr. Natale:
In your letter, dated April 1, 2025, you requested a binding tariff classification ruling on behalf of your client,
Perfect Remedy. The ruling was requested for paper shopping bags. Product information and a sample were
submitted for our review.
The product under consideration is shopping bags in multiple sizes. The sample measures approximately 8”
wide by 10” tall by 4.5” deep (front to back). The bag is solid color and embossed in gold with the Sotheby’s
trademark. The handles are 1”-wide woven twill fabric. The top edge of the bag is folded inward and the
fabric handles are threaded through slots and glued in place within the fold. The weight of the paper is not
identified. The bags are also imported in 10.5” by 13” by 4.25”, 14” by 14” by 5”, 18” by 18.5” by 7”, and 7
¾’ by 13 ¾” by 4” sizes.
The applicable subheading for each of the paper shopping bags except the 18” by 18.5” by 7” will be
4819.40.0040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Cartons,
boxes, cases, bags and other packing containers, of paper, paperboard, cellulose wadding or webs of cellulose
fibers; box files, letter trays and similar articles, of paper or paperboard of a kind used in offices, shops or the
like: Other sacks and bags, including cones: Other. The rate of duty will be free.
The applicable subheading for the paper shopping bags measuring 18” by 18.5” by 7” will be 4819.30.0040,
HTSUS, which provides for Cartons, boxes, cases, bags and other packing containers, of paper, paperboard,
cellulose wadding or webs of cellulose fibers; box files, letter trays and similar articles, of paper or
paperboard of a kind used in offices, shops or the like: Sacks and bags, having a base of a width of 40 cm or
more: Other. 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 subheading 4819.40.0040 or 4819.30.0040, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. At the time of entry, you
must report the Chapter 99 heading applicable to your product classification, 9903.01.63, in addition to
subheading 4819.40.0040 and 4819.30.0040, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 4819.40.0040, 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 4819.40.0040, HTSUS or 4819.30.0040, 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.
You ask whether the shopping bags are subject to antidumping and countervailing duties for paper shopping
bags from China (A570-152, C570-153). Written decisions regarding the scope of antidumping and
countervailing duties (AD/CVD) orders are issued by the Enforcement and Compliance office in the
International Trade Administration of the Department of Commerce (ITA) and are separate from tariff
classification and origin rulings issued by Customs and Border Protection (CBP). General information
regarding the ITA and AD/CVD can be found at
https://www.trade.gov/us-antidumping-and-countervailing-duties. The ITA’s “Guide on How to File for an
Antidumping/Countervailing Duty Scope Ruling Request” is available at
https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf
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, please contact
National Import Specialist Laurel Duvall at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division